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...
Rectification application rejected as assessee failed to raise issue of CIT(A)'s order lacking DIN before ITAT; assessee cannot rectify their own lapse. Addition upheld based on cash seized, not mere statement; CBDT instruction considered. Tax rate of 60% u/s 115BBE on undisclosed income upheld following precedent. Interest u/s 234A remanded to AO to allow adjustment of seized cash against tax liability before due date as per circular; interest u/s 234B decided. Relevant legal provisions, precedents, and reasoning provided.
Rectification application rejected as assessee failed to raise issue of CIT(A)'s order lacking DIN before ITAT; assessee cannot rectify their own lapse. Addition upheld based on cash seized, not mere statement; CBDT instruction considered. Tax rate of 60% u/s 115BBE on undisclosed income upheld following precedent. Interest u/s 234A remanded to AO to allow adjustment of seized cash against tax liability before due date as per circular; interest u/s 234B decided. Relevant legal provisions, precedents, and reasoning provided.
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