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...
Deduction of lease rent - lumpsum amount paid by the appellant/assessee for the entire tenure of the lease i.e. 99 years - matching principle - Given the facts obtaining in this case, the matching principle would have no applicability. The appellant/assessee chose to incur the liability of a crystallised amount in the period relevant to the AY in issue i.e. AY 2007-2008, and therefore, it was entitled to seek deduction of the amount which fulfilled the attributes - The expenditure was not in the nature of capital expenditure or a personal expense, It was expended fully and exclusively for the purposes of the business and; It did not fall within the realm of any provision of the Act which prohibited the appellant/assessee from claiming this deduction - HC
Deduction of lease rent - lumpsum amount paid by the appellant/assessee for the entire tenure of the lease i.e. 99 years - matching principle - Given the facts obtaining in this case, the matching principle would have no applicability. The appellant/assessee chose to incur the liability of a crystallised amount in the period relevant to the AY in issue i.e. AY 2007-2008, and therefore, it was entitled to seek deduction of the amount which fulfilled the attributes - The expenditure was not in the nature of capital expenditure or a personal expense, It was expended fully and exclusively for the purposes of the business and; It did not fall within the realm of any provision of the Act which prohibited the appellant/assessee from claiming this deduction - HC
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