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...
Non-resident company's receipts taxable u/s 44BB(2) excluding service tax/GST. Relying on Mitchell Drilling International Pty Limited case, service tax being statutory levy should not form part of gross receipts for computation u/s 44BB. Addition of service tax receipts to taxable income deleted. Appellate Tribunal upheld exclusion of service tax from gross receipts for presumptive taxation u/s 44BB.
Non-resident company's receipts taxable u/s 44BB(2) excluding service tax/GST. Relying on Mitchell Drilling International Pty Limited case, service tax being statutory levy should not form part of gross receipts for computation u/s 44BB. Addition of service tax receipts to taxable income deleted. Appellate Tribunal upheld exclusion of service tax from gross receipts for presumptive taxation u/s 44BB.
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