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...
Penalty proceedings u/s 270A - under reporting of the income - The Tribunal noted that the issue of depreciation on mining rights was debatable, supported by various judicial precedents favoring the allowance of depreciation. Considering the bona fide belief of the appellant, supported by legal precedents and the application for immunity under Section 270AA, the Tribunal upheld the CIT(A)'s decision to delete the penalty.
Penalty proceedings u/s 270A - under reporting of the income - The Tribunal noted that the issue of depreciation on mining rights was debatable, supported by various judicial precedents favoring the allowance of depreciation. Considering the bona fide belief of the appellant, supported by legal precedents and the application for immunity under Section 270AA, the Tribunal upheld the CIT(A)'s decision to delete the penalty.
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