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...
Reopening of assessment u/s 147 - assessment is in pursuance of an order on appeal, etc. u/s 150 - Already order of the Tribunal has been given effect to by the assessing officer for the assessment year 1995-96 by the consequential order dated 21.12.2005. That being the position, it was not open to the assessing officer to have once again issued a notice under Section 148 r.w.s. 150 of the Act to reopen the assessment for the assessment year 1995-96, that too, on a different issue unconnected with the order of the Tribunal. - HC
Reopening of assessment u/s 147 - assessment is in pursuance of an order on appeal, etc. u/s 150 - Already order of the Tribunal has been given effect to by the assessing officer for the assessment year 1995-96 by the consequential order dated 21.12.2005. That being the position, it was not open to the assessing officer to have once again issued a notice under Section 148 r.w.s. 150 of the Act to reopen the assessment for the assessment year 1995-96, that too, on a different issue unconnected with the order of the Tribunal. - HC
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