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 ITAT set aside the CIT(A)'s order regarding the sale of sugar at concessional rates by a cooperative sugar factory. While acknowledging the customary practice of selling sugar at concessional rates to farmers, the Tribunal noted that the assessee failed to specify the number of members and non-members who received such concessions. The Sugar Commissioner's directions under Section 79(A) of Maharashtra Co-operative Societies Act, 1960 permitted sale of maximum 5 kg sugar monthly at concessional rates only to members who supplied sugarcane. The matter was remanded for denovo adjudication, requiring CIT(A) to analyze specific facts in light of the Supreme Court's decision in Krishna SSK Ltd. Appeal allowed for statistical purposes.
The ITAT set aside the CIT(A)'s order regarding the sale of sugar at concessional rates by a cooperative sugar factory. While acknowledging the customary practice of selling sugar at concessional rates to farmers, the Tribunal noted that the assessee failed to specify the number of members and non-members who received such concessions. The Sugar Commissioner's directions under Section 79(A) of Maharashtra Co-operative Societies Act, 1960 permitted sale of maximum 5 kg sugar monthly at concessional rates only to members who supplied sugarcane. The matter was remanded for denovo adjudication, requiring CIT(A) to analyze specific facts in light of the Supreme Court's decision in Krishna SSK Ltd. Appeal allowed for statistical purposes.
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