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...
Assessee included excess stock of diamonds found during survey under "Income from Other Sources" and paid normal tax. PCIT held income should be taxed u/s 69B as unexplained investment, attracting higher tax u/s 115BBE. AO completed assessment without mentioning survey operations or examining assessee's claim. ITAT held AO failed to make proper enquiry before allowing the claim, making order amenable to revision u/s 263. ITAT directed AO to examine issue afresh regarding taxability of income offered during survey and decide in accordance with law. Assessee's appeal dismissed.
Assessee included excess stock of diamonds found during survey under "Income from Other Sources" and paid normal tax. PCIT held income should be taxed u/s 69B as unexplained investment, attracting higher tax u/s 115BBE. AO completed assessment without mentioning survey operations or examining assessee's claim. ITAT held AO failed to make proper enquiry before allowing the claim, making order amenable to revision u/s 263. ITAT directed AO to examine issue afresh regarding taxability of income offered during survey and decide in accordance with law. Assessee's appeal dismissed.
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