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...
Revision u/s 263 by CIT - set off of brought forward business loss from the income assessable under the head 'Capital Gain' - gain of depreciable assets by entering into long term lease agreement - the loss assessed under the head ‘Profits & Gains of Business or Profession’ in the preceding years and brought forward to the relevant year had been rightly claimed as set off against the profits or gain derived from long term leases assessed under the head 'Short Term Capital Gain'. - AT
Revision u/s 263 by CIT - set off of brought forward business loss from the income assessable under the head 'Capital Gain' - gain of depreciable assets by entering into long term lease agreement - the loss assessed under the head ‘Profits & Gains of Business or Profession’ in the preceding years and brought forward to the relevant year had been rightly claimed as set off against the profits or gain derived from long term leases assessed under the head 'Short Term Capital Gain'. - AT
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