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 56(2)(x) arises when consideration paid for immovable property is less than stamp duty value by more than Rs. 50,000 or 10% of consideration. If agreement fixing consideration was prior to the relevant year, stamp duty value on agreement date is considered. Section 50C applies to seller, 56(2)(x) to buyer. 10% tolerance limit under 50C also applies to 56(2)(x). Assessee is allowed 10% tolerance limit benefit since inception of 56(2)(x) and 50C. Addition made by Assessing Officer not in accordance with law, directed to delete addition. Assessee appeal allowed.
Addition u/s 56(2)(x) arises when consideration paid for immovable property is less than stamp duty value by more than Rs. 50,000 or 10% of consideration. If agreement fixing consideration was prior to the relevant year, stamp duty value on agreement date is considered. Section 50C applies to seller, 56(2)(x) to buyer. 10% tolerance limit under 50C also applies to 56(2)(x). Assessee is allowed 10% tolerance limit benefit since inception of 56(2)(x) and 50C. Addition made by Assessing Officer not in accordance with law, directed to delete addition. Assessee appeal allowed.
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