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...
Assessment u/s 153A - Validity examined. Assessments cannot be framed without incriminating material found during search u/s 132. Completed assessments u/s 143(3) cannot be reopened u/s 153A without relevant seized material. Assessing Officer directed to examine relevance of seized material for assessment years 2011-12 and 2012-13. Jurisdiction u/s 132(1) upheld considering retrospective amendment. Assessee entitled to revise position, additions cannot be solely based on statement u/s 132(4) without corroborative evidence. Additional evidence admitted, Assessing Officer to re-examine in light of new evidence. Approval u/s 153D not found mechanical. Notice u/s 153A for assessment years 2011-12 and 2012-13 may be barred by limitation, matter restored to Assessing Officer to decide after examining handover date of seized documents.
Assessment u/s 153A - Validity examined. Assessments cannot be framed without incriminating material found during search u/s 132. Completed assessments u/s 143(3) cannot be reopened u/s 153A without relevant seized material. Assessing Officer directed to examine relevance of seized material for assessment years 2011-12 and 2012-13. Jurisdiction u/s 132(1) upheld considering retrospective amendment. Assessee entitled to revise position, additions cannot be solely based on statement u/s 132(4) without corroborative evidence. Additional evidence admitted, Assessing Officer to re-examine in light of new evidence. Approval u/s 153D not found mechanical. Notice u/s 153A for assessment years 2011-12 and 2012-13 may be barred by limitation, matter restored to Assessing Officer to decide after examining handover date of seized documents.
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