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 allowed assessee's appeal for statistical purposes and restored issue of disallowance of interest expenditure against minor son's interest income to AO for fresh adjudication after proper inquiry regarding alleged loans taken by minor, observing AO's findings were cryptic and CIT(A) passed impugned order based on shallow assessment order.
ITAT allowed assessee's appeal for statistical purposes and restored issue of disallowance of interest expenditure against minor son's interest income to AO for fresh adjudication after proper inquiry regarding alleged loans taken by minor, observing AO's findings were cryptic and CIT(A) passed impugned order based on shallow assessment order.
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