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...
TP Adjustment - comparable selection - The High Court upheld the ITAT's decision, emphasizing the principle of comparing entities with similar characteristics. It acknowledged the appellant's argument that the comparables had been in business for many years, whereas the appellant had only started operations recently. The High Court agreed that comparing entities with different operational histories was inappropriate. It noted that the appellant's expenses were similar to those of subsequent years when sales had increased, indicating business stabilization.
TP Adjustment - comparable selection - The High Court upheld the ITAT's decision, emphasizing the principle of comparing entities with similar characteristics. It acknowledged the appellant's argument that the comparables had been in business for many years, whereas the appellant had only started operations recently. The High Court agreed that comparing entities with different operational histories was inappropriate. It noted that the appellant's expenses were similar to those of subsequent years when sales had increased, indicating business stabilization.
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