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...
The High Court quashed the order of the Interim Board for Settlement (IBS) rejecting the petitioner's settlement application u/s 245D(4). The court held that the IBS should consider the application, keeping open all objections/contentions of the revenue, including on the applicable threshold limits under the first proviso to Section 245C(1). The court did not examine the petitioner's challenge to the constitutional validity of these provisions, and all contentions of the petitioner were expressly kept open. The writ petition was disposed of without costs.
The High Court quashed the order of the Interim Board for Settlement (IBS) rejecting the petitioner's settlement application u/s 245D(4). The court held that the IBS should consider the application, keeping open all objections/contentions of the revenue, including on the applicable threshold limits under the first proviso to Section 245C(1). The court did not examine the petitioner's challenge to the constitutional validity of these provisions, and all contentions of the petitioner were expressly kept open. The writ petition was disposed of without costs.
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