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...
Validity of 158BD proceedings - prior to 04.09.1997, i.e., the date on which jurisdiction u/s 158BD was assumed, the books of account were not handed over to the assessee. - Since the AO in the instant case has taken recourse to section 158BD before receipt of the seized material, therefore, the 158BD jurisdictional conditions cannot be said to have been met. Therefore, the entire proceedings u/s 158BD/143(3) are vitiated and, therefore, such 158BD proceedings which are not in accordance with the law are quashed - AT
Validity of 158BD proceedings - prior to 04.09.1997, i.e., the date on which jurisdiction u/s 158BD was assumed, the books of account were not handed over to the assessee. - Since the AO in the instant case has taken recourse to section 158BD before receipt of the seized material, therefore, the 158BD jurisdictional conditions cannot be said to have been met. Therefore, the entire proceedings u/s 158BD/143(3) are vitiated and, therefore, such 158BD proceedings which are not in accordance with the law are quashed - AT
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