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...
Addition u/s 56(2)(vii)(b) - Difference between the agreed consideration and Valuation adopted by the DVO - Assessee is one of the party who along with four others entered into a deed of conveyance for purchase of property being land - The ITAT held that, the Assessee received 1/5th share in the above property in excess of agreed consideration. Therefore, the addition in the hands of the Assessee can only be made at the rate of 1/5th of the above difference amount.
Addition u/s 56(2)(vii)(b) - Difference between the agreed consideration and Valuation adopted by the DVO - Assessee is one of the party who along with four others entered into a deed of conveyance for purchase of property being land - The ITAT held that, the Assessee received 1/5th share in the above property in excess of agreed consideration. Therefore, the addition in the hands of the Assessee can only be made at the rate of 1/5th of the above difference amount.
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