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...
Assessment u/s 144B - Disallowance of commission paid to the Foreign Company and Local Agents/Parties and expenses incurred by the petitioner on account of purchase of bullion - The High court noted the petitioner's failure to satisfactorily explain the disallowed commission payments and purchases. It was highlighted that the petitioner did not provide necessary documents, such as GST returns in Form GST 2A, to substantiate the transactions. - Writ Petition dismissed.
Assessment u/s 144B - Disallowance of commission paid to the Foreign Company and Local Agents/Parties and expenses incurred by the petitioner on account of purchase of bullion - The High court noted the petitioner's failure to satisfactorily explain the disallowed commission payments and purchases. It was highlighted that the petitioner did not provide necessary documents, such as GST returns in Form GST 2A, to substantiate the transactions. - Writ Petition dismissed.
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