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...
Entitled to registration u/s 12AA and approval under Section 80G - Allegation of charging higher rate of interest from the self help groups in the name of charitable activity - Revenue submits that the CIT recorded a finding that the interest charged would be 35% - we find that there is nothing on record to show that the assessee has charged 35% interest. The interest charged is at 15% per annum and 20% is charged as service charges and obviously, the service charges cannot be on recurring basis - Order of ITAT granting relief to assessee sustained - HC
Entitled to registration u/s 12AA and approval under Section 80G - Allegation of charging higher rate of interest from the self help groups in the name of charitable activity - Revenue submits that the CIT recorded a finding that the interest charged would be 35% - we find that there is nothing on record to show that the assessee has charged 35% interest. The interest charged is at 15% per annum and 20% is charged as service charges and obviously, the service charges cannot be on recurring basis - Order of ITAT granting relief to assessee sustained - HC
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