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 68 addition deleted - Assessee discharged onus to explain identity, creditworthiness of loan creditors and genuineness of transactions by providing voluminous evidence. Loans received were repaid during the year or subsequent year. Non-payment of interest alone cannot justify addition u/s 68. Section 14A disallowance deleted - Investments made from own funds and non-interest borrowings, following Supreme Court and High Court precedents. Interest disallowance on advances deleted - Advances given from own funds and non-interest borrowings, relying on High Court judgment. Write-off of advance on project abandonment allowed as business expenditure based on High Court decision. Revenue appeal dismissed by ITAT.
Section 68 addition deleted - Assessee discharged onus to explain identity, creditworthiness of loan creditors and genuineness of transactions by providing voluminous evidence. Loans received were repaid during the year or subsequent year. Non-payment of interest alone cannot justify addition u/s 68. Section 14A disallowance deleted - Investments made from own funds and non-interest borrowings, following Supreme Court and High Court precedents. Interest disallowance on advances deleted - Advances given from own funds and non-interest borrowings, relying on High Court judgment. Write-off of advance on project abandonment allowed as business expenditure based on High Court decision. Revenue appeal dismissed by ITAT.
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