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...
Addition u/s 69A r.w.s 115BBE - unexplained gold jewellery found at the time of search - the assessee cannot be asked to explain the bank transactions of an unrelated party. Evidences in the form of confirmation, books of account, stock register and ledger account along with bank statement cannot be brushed aside lightly and considering these evidences, we do not find any merit in the impugned addition made u/s 69A - AO directed to delete the addition - AT
Addition u/s 69A r.w.s 115BBE - unexplained gold jewellery found at the time of search - the assessee cannot be asked to explain the bank transactions of an unrelated party. Evidences in the form of confirmation, books of account, stock register and ledger account along with bank statement cannot be brushed aside lightly and considering these evidences, we do not find any merit in the impugned addition made u/s 69A - AO directed to delete the addition - AT
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