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...
Benami transaction case involving beneficial ownership of currency seized. Appellant argued lack of evidence to prove beneficial ownership. Court held initial statement under Income Tax Act corroborated by Bikky Kumar Singh, quoted in impugned order, showing appellant's involvement. Appellant disowned currency but filing appeal indicates interest. Court found material on record considered by Adjudicating Authority, rejecting first argument. Delay in recording subsequent statement under Benami Act not an issue in absence of statutory period mandate. On adjudication timeline, court clarified reference received in April 2018, notice issued same month, order passed within one year from month-end of reference receipt as required u/s 26(7). Notice copy given to beneficial owner as per Section 24(2) requirement, appellant admitting receipt. Competent Authority approval for continuing provisional attachment as required u/s 24(4)(a)(i) found on record. All arguments rejected, appeal dismissed.
Benami transaction case involving beneficial ownership of currency seized. Appellant argued lack of evidence to prove beneficial ownership. Court held initial statement under Income Tax Act corroborated by Bikky Kumar Singh, quoted in impugned order, showing appellant's involvement. Appellant disowned currency but filing appeal indicates interest. Court found material on record considered by Adjudicating Authority, rejecting first argument. Delay in recording subsequent statement under Benami Act not an issue in absence of statutory period mandate. On adjudication timeline, court clarified reference received in April 2018, notice issued same month, order passed within one year from month-end of reference receipt as required u/s 26(7). Notice copy given to beneficial owner as per Section 24(2) requirement, appellant admitting receipt. Competent Authority approval for continuing provisional attachment as required u/s 24(4)(a)(i) found on record. All arguments rejected, appeal dismissed.
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