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...
Validity of Revision u/s 263 - PCIT was of the view that the cash withdrawn was utilised to purchase inventory - if the AO did not bring to tax the amount which was adverted to in the “reason to believe” framed in the first instance, then the PCIT could not have triggered proceedings for cash withdrawals u/s 263 of the Act. - HC
Validity of Revision u/s 263 - PCIT was of the view that the cash withdrawn was utilised to purchase inventory - if the AO did not bring to tax the amount which was adverted to in the “reason to believe” framed in the first instance, then the PCIT could not have triggered proceedings for cash withdrawals u/s 263 of the Act. - HC
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