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...
Penalty u/s 271(1)(c) - Transfer Pricing adjustment made - applying the analysis of the term ‘good faith’ and ‘due diligence’ we are of the considered view that in the present case the assessee has computed the ALP in respect of the international transaction in good faith and with due diligence. Accordingly, we find no infirmity in the impugned order passed by the learned CIT(A) directing deletion of penalty levied under section 271(1)(c) - AT
Penalty u/s 271(1)(c) - Transfer Pricing adjustment made - applying the analysis of the term ‘good faith’ and ‘due diligence’ we are of the considered view that in the present case the assessee has computed the ALP in respect of the international transaction in good faith and with due diligence. Accordingly, we find no infirmity in the impugned order passed by the learned CIT(A) directing deletion of penalty levied under section 271(1)(c) - AT
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