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...
Reassessment proceedings invalidated due to improper sanctioning authority. Sanction accorded by Principal Commissioner instead of Principal Chief Commissioner as mandated for cases beyond three years u/s 151(ii). Proviso to Section 151 inserting revised sanctioning authorities effective April 1, 2023, inapplicable. Impugned order and notice quashed, decided in assessee's favor, following Siemens Financial Services Private Limited case.
Reassessment proceedings invalidated due to improper sanctioning authority. Sanction accorded by Principal Commissioner instead of Principal Chief Commissioner as mandated for cases beyond three years u/s 151(ii). Proviso to Section 151 inserting revised sanctioning authorities effective April 1, 2023, inapplicable. Impugned order and notice quashed, decided in assessee's favor, following Siemens Financial Services Private Limited case.
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