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 - Nature of capital gain - On going through the copy of the purchase deed of the said land, we find that direct possession of the land in question had been handed over/transferred to the appellant being one of the co-owners/ purchaser of the land on 17–04–2008 only and not on 17–05–2010 as presumed by PCIT. - order passed by the assessing officer is neither erroneous nor prejudicial to the interest of Revenue. - AT
Revision u/s 263 - Nature of capital gain - On going through the copy of the purchase deed of the said land, we find that direct possession of the land in question had been handed over/transferred to the appellant being one of the co-owners/ purchaser of the land on 17–04–2008 only and not on 17–05–2010 as presumed by PCIT. - order passed by the assessing officer is neither erroneous nor prejudicial to the interest of Revenue. - AT
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