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...
Validity of assessment order - rectification of mistake - error apparent on the face of record - The petitioner has not claimed that the original invoice has already been produced before the Revenue. What is stated by the petitioner is that, the petitioner has traced the original invoice and it is readily available with them to produce the same - this Court has no hesitation to hold that the impugned order does not survive under the legal scrutiny. - Matter restored back - HC
Validity of assessment order - rectification of mistake - error apparent on the face of record - The petitioner has not claimed that the original invoice has already been produced before the Revenue. What is stated by the petitioner is that, the petitioner has traced the original invoice and it is readily available with them to produce the same - this Court has no hesitation to hold that the impugned order does not survive under the legal scrutiny. - Matter restored back - HC
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