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...
Waiver of interest u/s 220(2A) - The Revenue in the present case recorded the non-cooperation of the petitioner assessee. The observations made in this regard would establish that consequent to search notice under Section 153A of the Income Tax Act dated 09.03.2011 calling for return of income within 45 days of the receipt of the notice. But the assessee furnished the return of income only on 15.07.2011. The other incidents are also recorded to establish that the petitioner assessee had not cooperated for the completion of the Income Tax proceedings. - No relief - HC
Waiver of interest u/s 220(2A) - The Revenue in the present case recorded the non-cooperation of the petitioner assessee. The observations made in this regard would establish that consequent to search notice under Section 153A of the Income Tax Act dated 09.03.2011 calling for return of income within 45 days of the receipt of the notice. But the assessee furnished the return of income only on 15.07.2011. The other incidents are also recorded to establish that the petitioner assessee had not cooperated for the completion of the Income Tax proceedings. - No relief - HC
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