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...
Estimation of income - bogus purchases - The Revenue argued that when purchases are proven bogus, the entire amount should be added to the income. However, the court cited precedents and upheld the ITAT's decision, stating that the factual finding of 8% as a fair profit margin was reasonable and in line with established legal principles.
Estimation of income - bogus purchases - The Revenue argued that when purchases are proven bogus, the entire amount should be added to the income. However, the court cited precedents and upheld the ITAT's decision, stating that the factual finding of 8% as a fair profit margin was reasonable and in line with established legal principles.
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