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...
The High Court reviewed a case involving a rough assessment of tax quantum and the validity of a Best judgment assessment for determining net profit in a civil work contract. The assessing officer acknowledged the receipt of consideration for civil work, which was supported by materials not disputed. The ITAT noted the net profit rates of the past seven years and comparable rates in the trade, settling on a rate of 8% agreed upon by the assessee. The court found no fault in the application of the 8% net profit rate, upholding the ITAT's decision as legally sound. The judgment favored the assessee based on best judgment assessment principles.
The High Court reviewed a case involving a rough assessment of tax quantum and the validity of a Best judgment assessment for determining net profit in a civil work contract. The assessing officer acknowledged the receipt of consideration for civil work, which was supported by materials not disputed. The ITAT noted the net profit rates of the past seven years and comparable rates in the trade, settling on a rate of 8% agreed upon by the assessee. The court found no fault in the application of the 8% net profit rate, upholding the ITAT's decision as legally sound. The judgment favored the assessee based on best judgment assessment principles.
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