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 of book profit u/s 115JB - Disputed central excise demand raised against the assessee - denial of writing back benefit to the assessee - We appreciate and accept the conclusion recorded by the Tribunal by taking note of the fact that the assessee was subjected to the slab rate of 30% for the assessment years 1997-1998 and 1998-1999 and computed the tax payable thereon under normal provisions. The denial of writing back benefit to the assessee in these assessment years are illegal and the finding recorded by the Tribunal is valid - HC
MAT Computation of book profit u/s 115JB - Disputed central excise demand raised against the assessee - denial of writing back benefit to the assessee - We appreciate and accept the conclusion recorded by the Tribunal by taking note of the fact that the assessee was subjected to the slab rate of 30% for the assessment years 1997-1998 and 1998-1999 and computed the tax payable thereon under normal provisions. The denial of writing back benefit to the assessee in these assessment years are illegal and the finding recorded by the Tribunal is valid - HC
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