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...
Deduction claimed u/s 54F OR 54 - Investment of LTCG - Owning more than one house property - CIT(A) deleted the addition considering the same u/s 54 - Assessee revised the claim of exemption from u/s 54F to u/s 54 in appeal - Assessee specifically claimed deduction u/s 54 only in the return filed in response to notice u/s 148. Therefore by no stretch of imagination, the claim of the assessee could be treated as fresh claim. - AT
Deduction claimed u/s 54F OR 54 - Investment of LTCG - Owning more than one house property - CIT(A) deleted the addition considering the same u/s 54 - Assessee revised the claim of exemption from u/s 54F to u/s 54 in appeal - Assessee specifically claimed deduction u/s 54 only in the return filed in response to notice u/s 148. Therefore by no stretch of imagination, the claim of the assessee could be treated as fresh claim. - AT
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