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...
Nature of expenses - Allowable expenses u/s 37(1) - Interest and late fee on TDS, Late payment & penalty charges, Interest on margin trading facility - There was no basis with the AO/ld.CIT(A) to hold that these expenses were in the nature of penalty/expenses for any purpose being an offence or which is prohibited by law, not allowed in terms of Explanation to section 37(1) - AT
Nature of expenses - Allowable expenses u/s 37(1) - Interest and late fee on TDS, Late payment & penalty charges, Interest on margin trading facility - There was no basis with the AO/ld.CIT(A) to hold that these expenses were in the nature of penalty/expenses for any purpose being an offence or which is prohibited by law, not allowed in terms of Explanation to section 37(1) - AT
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