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...
Monetary limit for filing appeals before High Court not breached for assessment years 2006-07 to 2010-11, appeals dismissed as not maintainable. For assessment years 2011-12 and 2012-13, tax effect exceeds monetary limit but fundamental issue regarding availability of exemption to Trust u/s 12AA already decided in Trust's favor, questions of law raised by revenue answered against revenue in Trust's favor.
Monetary limit for filing appeals before High Court not breached for assessment years 2006-07 to 2010-11, appeals dismissed as not maintainable. For assessment years 2011-12 and 2012-13, tax effect exceeds monetary limit but fundamental issue regarding availability of exemption to Trust u/s 12AA already decided in Trust's favor, questions of law raised by revenue answered against revenue in Trust's favor.
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