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 Assessment u/s 153A - This absence of incriminating material played a pivotal role in the decision. Citing the precedent established by the Hon’ble Supreme Court in the case of PCIT vs. Abhisar Buildwell Pvt. Ltd., the Tax Tribunal held that the additions made by the AO, which had been subsequently confirmed by the Ld. CIT(A), were to be deleted due to their lack of foundation in incriminating evidence.
Validity of Assessment u/s 153A - This absence of incriminating material played a pivotal role in the decision. Citing the precedent established by the Hon’ble Supreme Court in the case of PCIT vs. Abhisar Buildwell Pvt. Ltd., the Tax Tribunal held that the additions made by the AO, which had been subsequently confirmed by the Ld. CIT(A), were to be deleted due to their lack of foundation in incriminating evidence.
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