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...
MAT Computation u/s 115JB - Revisions proceedings u/s 263 - CIT directed the AO to make certain additions to book profit u/s 115JB - What we find is in the order passed by CIT, there is no mention any where as to under which category of the explanation A to K below Sub Section 2 of Section 115 JB of the Act these four items mentioned above would fall. - Without identifying under which part of the list disputed four items form part of CIT could not have exercised its revisionary powers. - HC
MAT Computation u/s 115JB - Revisions proceedings u/s 263 - CIT directed the AO to make certain additions to book profit u/s 115JB - What we find is in the order passed by CIT, there is no mention any where as to under which category of the explanation A to K below Sub Section 2 of Section 115 JB of the Act these four items mentioned above would fall. - Without identifying under which part of the list disputed four items form part of CIT could not have exercised its revisionary powers. - HC
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