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...
Section 80CCC(2) applies only when the assessee has claimed and been allowed a deduction u/s 80CCC(1). Since the assessee did not claim deduction u/s 80CCC(1), Section 80CCC(2) is inapplicable. The accretion of Rs. 16,39,726 from premature surrender of pension policies requires examination u/s 10(10D) to determine eligibility for exemption. The matter is restored to the Assessing Officer to examine the exemption eligibility u/s 10(10D). The assessee's appeal is partly allowed.
Section 80CCC(2) applies only when the assessee has claimed and been allowed a deduction u/s 80CCC(1). Since the assessee did not claim deduction u/s 80CCC(1), Section 80CCC(2) is inapplicable. The accretion of Rs. 16,39,726 from premature surrender of pension policies requires examination u/s 10(10D) to determine eligibility for exemption. The matter is restored to the Assessing Officer to examine the exemption eligibility u/s 10(10D). The assessee's appeal is partly allowed.
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