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 69 r.w.s. 115BBE - Higher rate of tax treating the surrendered income as unexplained investment / income - Amount surrendered during a survey due to stock discrepancies and an excess cash amount. - The Tribunal concluded that since the income from the surrendered stock was from regular business operations, it should not be taxed under the harsher provisions of Section 115BBE. They pointed out that the Assessee's books were audited and no discrepancies other than those already declared were found. Thus, the addition made by the AO under Section 115BBE was overturned.
Addition u/s 69 r.w.s. 115BBE - Higher rate of tax treating the surrendered income as unexplained investment / income - Amount surrendered during a survey due to stock discrepancies and an excess cash amount. - The Tribunal concluded that since the income from the surrendered stock was from regular business operations, it should not be taxed under the harsher provisions of Section 115BBE. They pointed out that the Assessee's books were audited and no discrepancies other than those already declared were found. Thus, the addition made by the AO under Section 115BBE was overturned.
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