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...
Interest u/ss 234A, 234B, and 234C cannot be charged post Corporate Insolvency Resolution Process when the amount has been frozen by moratorium under IBC and not part of the approved Resolution Plan. Claims not included in the Resolution Plan stand extinguished, and no proceedings can be initiated for such claims. The order charging interest and the consequent demand notice were quashed, and the petitioner is entitled to a refund of the amount paid for the relevant assessment year.
Interest u/ss 234A, 234B, and 234C cannot be charged post Corporate Insolvency Resolution Process when the amount has been frozen by moratorium under IBC and not part of the approved Resolution Plan. Claims not included in the Resolution Plan stand extinguished, and no proceedings can be initiated for such claims. The order charging interest and the consequent demand notice were quashed, and the petitioner is entitled to a refund of the amount paid for the relevant assessment year.
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