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...
HC rejected a challenge to the amended definition of "Sikkimese" under Explanation (v) to Section 10(26AAA) of Income Tax Act introduced by Finance Act, 2023. The Court determined that the definition applies exclusively for income tax purposes and does not impact rights and privileges of indigenous Sikkimese protected under Article 371F(k) of the Constitution. The Court relied on the April 4, 2023 Press Release clarifying the limited scope of the definition, finding no justifiable reason to entertain the writ petition challenging the amendment's constitutional validity.
HC rejected a challenge to the amended definition of "Sikkimese" under Explanation (v) to Section 10(26AAA) of Income Tax Act introduced by Finance Act, 2023. The Court determined that the definition applies exclusively for income tax purposes and does not impact rights and privileges of indigenous Sikkimese protected under Article 371F(k) of the Constitution. The Court relied on the April 4, 2023 Press Release clarifying the limited scope of the definition, finding no justifiable reason to entertain the writ petition challenging the amendment's constitutional validity.
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