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 69 - CIT confirmed the additions by Changing the section to section 69C - Addition made by the AO u/s 69 of the Act cannot be converted into Sec. 69C of the Act by the Ld.CIT(A) while upholding the addition. Action of the Ld.CIT(A) in this regard cannot be held as valid and sustainable being bad in law. - AT
Addition u/s 69 - CIT confirmed the additions by Changing the section to section 69C - Addition made by the AO u/s 69 of the Act cannot be converted into Sec. 69C of the Act by the Ld.CIT(A) while upholding the addition. Action of the Ld.CIT(A) in this regard cannot be held as valid and sustainable being bad in law. - AT
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