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...
Transfer pricing adjustment regarding inclusion of E4e Healthcare as a comparable company. Assessee objected due to unavailability of annual report. However, objections were not adjudicated as Transfer Pricing Officer determined arm's length price adjustment as nil for the relevant year. Assessee's contention that E4e Healthcare is functionally dissimilar and cannot be included as a comparable was not considered by any authority. Orders passed by authorities were based on incorrect assumptions.
Transfer pricing adjustment regarding inclusion of E4e Healthcare as a comparable company. Assessee objected due to unavailability of annual report. However, objections were not adjudicated as Transfer Pricing Officer determined arm's length price adjustment as nil for the relevant year. Assessee's contention that E4e Healthcare is functionally dissimilar and cannot be included as a comparable was not considered by any authority. Orders passed by authorities were based on incorrect assumptions.
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