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 153A was made for deemed dividend u/s 2(22)(e). However, following Abhisar Buildwell P. Ltd. [2023 (4) TMI 1056 - Supreme Court], the High Court held that the Assessing Officer would not be justified to assess income in the absence of incriminating material found during the search. As no such incriminating material was placed before the Court, the substantial questions of law were answered against the Revenue, affirming the Appellate Tribunal's order.
Addition u/s 153A was made for deemed dividend u/s 2(22)(e). However, following Abhisar Buildwell P. Ltd. [2023 (4) TMI 1056 - Supreme Court], the High Court held that the Assessing Officer would not be justified to assess income in the absence of incriminating material found during the search. As no such incriminating material was placed before the Court, the substantial questions of law were answered against the Revenue, affirming the Appellate Tribunal's order.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4830 
Join Channel 
