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...
Exemption u/s 11 - benefit of registration granted u/s.12A of the Act from AY 2019-20, would be available for earlier years also that are pending as on the date of grant of registration as per the 1st proviso to Sec.12A(2) the denial of benefit of exemption u/s.11 on the ground of absence of registration u/s.12A of the Act, cannot be sustained. - AT
Exemption u/s 11 - benefit of registration granted u/s.12A of the Act from AY 2019-20, would be available for earlier years also that are pending as on the date of grant of registration as per the 1st proviso to Sec.12A(2) the denial of benefit of exemption u/s.11 on the ground of absence of registration u/s.12A of the Act, cannot be sustained. - AT
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