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...
AO determined commission from alleged bogus purchases and sales, made addition. ITAT held AO should have either rejected books of account and determined actual profit, or retained returned income without making presumptive addition. AO cannot presume additional income without being actually earned by assessee. Gross taxable income cannot be less than returned income filed u/s 139(1). ITAT deleted AO's additions, decided in favour of assessee.
AO determined commission from alleged bogus purchases and sales, made addition. ITAT held AO should have either rejected books of account and determined actual profit, or retained returned income without making presumptive addition. AO cannot presume additional income without being actually earned by assessee. Gross taxable income cannot be less than returned income filed u/s 139(1). ITAT deleted AO's additions, decided in favour of assessee.
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