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...
ITAT held that interest on refund is payable till the date funds are released to assessee, not till date of order accepting refund claim. Relying on Delhi HC's Nokia ruling, ITAT directed AO/CPC to grant interest to assessee till 30-01-2024 when refund was actually released after order u/s 154, as 'refund granted' in Sec 244A means refund payment, not just order accepting refund claim. Interest compensates for time value of money.
ITAT held that interest on refund is payable till the date funds are released to assessee, not till date of order accepting refund claim. Relying on Delhi HC's Nokia ruling, ITAT directed AO/CPC to grant interest to assessee till 30-01-2024 when refund was actually released after order u/s 154, as 'refund granted' in Sec 244A means refund payment, not just order accepting refund claim. Interest compensates for time value of money.
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