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...
Unexplained cash deposit in the Bank A/c - in the subsequent assessment year the A.O. himself has accepted that the S.B. A/c of the assessee is used for his business transactions and since the assessee has opted for presumptive taxation under section 44AF lower authorities are not justified in sustaining the addition as unexplained cash deposit in the Bank - AT
Unexplained cash deposit in the Bank A/c - in the subsequent assessment year the A.O. himself has accepted that the S.B. A/c of the assessee is used for his business transactions and since the assessee has opted for presumptive taxation under section 44AF lower authorities are not justified in sustaining the addition as unexplained cash deposit in the Bank - AT
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