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...
Rectification of mistake - Levy penalty u/s 271AAC or u/s 270 - No proceedings are pending before the CIT(A) - CIT (A) was not right in passing order of rectification by directing to initiate the penalty proceedings u/s 270A in place of penalty proceedings u/s 271AAC when admittedly vide her initial order dated 28.02.2022 has categorically held that addition made on account of alleged unaccounted sale u/s 68 is totally unjustified and consequently not covered u/s 115BBE of the Act and there was no income chargeable to tax under section 115BBE. - AT
Rectification of mistake - Levy penalty u/s 271AAC or u/s 270 - No proceedings are pending before the CIT(A) - CIT (A) was not right in passing order of rectification by directing to initiate the penalty proceedings u/s 270A in place of penalty proceedings u/s 271AAC when admittedly vide her initial order dated 28.02.2022 has categorically held that addition made on account of alleged unaccounted sale u/s 68 is totally unjustified and consequently not covered u/s 115BBE of the Act and there was no income chargeable to tax under section 115BBE. - AT
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