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...
Stay of demand - We are of the view that rejection of the stay-application is nothing but harassment to the assessee as there is no distinction between the facts of the pending appeals from the order of the Tribunal and CIT(Appeals) rendered in favour of the assessee for the earlier years and hence, CIT (Appeals) is bound to follow the order of the Tribunal for earlier years. - HC
Stay of demand - We are of the view that rejection of the stay-application is nothing but harassment to the assessee as there is no distinction between the facts of the pending appeals from the order of the Tribunal and CIT(Appeals) rendered in favour of the assessee for the earlier years and hence, CIT (Appeals) is bound to follow the order of the Tribunal for earlier years. - HC
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