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...
The SC permitted petitioners to challenge the assessment order for AY 2022-2023 before CIT (Appeals) with an application for stay and waiver of the 20% deposit requirement under CBDT Office Memoranda dated 29.02.2016 and 31.07.2017. The Court directed that if an appeal is filed within five days, it should not be dismissed on grounds of limitation, considering petitioners had previously approached the High Court. The SC also ordered that no coercive recovery measures be taken for ten days. The Court noted that 30% of the tax demand for AY 2021-2022 had already been recovered through coercive measures. The SLP was disposed of accordingly.
The SC permitted petitioners to challenge the assessment order for AY 2022-2023 before CIT (Appeals) with an application for stay and waiver of the 20% deposit requirement under CBDT Office Memoranda dated 29.02.2016 and 31.07.2017. The Court directed that if an appeal is filed within five days, it should not be dismissed on grounds of limitation, considering petitioners had previously approached the High Court. The SC also ordered that no coercive recovery measures be taken for ten days. The Court noted that 30% of the tax demand for AY 2021-2022 had already been recovered through coercive measures. The SLP was disposed of accordingly.
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