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...
Bogus LTCG - disallowance of exemption claimed by assessee u/s 10(38) on account of LTCG - there is no live link in the order of SEBI about the transactions of shares of assessee under scrutiny, so such order cannot be read against the assessee in absence of ant corroborative evidence. In fact there is no evidence on record that the assessee made any prearranged transactions. - Additions deleted - AT
Bogus LTCG - disallowance of exemption claimed by assessee u/s 10(38) on account of LTCG - there is no live link in the order of SEBI about the transactions of shares of assessee under scrutiny, so such order cannot be read against the assessee in absence of ant corroborative evidence. In fact there is no evidence on record that the assessee made any prearranged transactions. - Additions deleted - AT
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