TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Unjust adjustment of excess refunds - intimation ought to be given to the assessee before making an adjustment of refund towards pending tax dues u/s 245 - The respondents defence for not issuing Section 245 Intimation before making adjustment was that subsequently on 13.05.2020 such intimation was issued under Section 143(1) of the Act, but the said Intimation is not valid in law - HC
Unjust adjustment of excess refunds - intimation ought to be given to the assessee before making an adjustment of refund towards pending tax dues u/s 245 - The respondents defence for not issuing Section 245 Intimation before making adjustment was that subsequently on 13.05.2020 such intimation was issued under Section 143(1) of the Act, but the said Intimation is not valid in law - HC
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