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...
In a tax dispute before ITAT involving search and survey operations by CGST authorities, the tribunal examined allegations of bogus purchases based on incriminating evidence discovered during investigations. The tribunal found substantial materials supporting tax authorities' disallowances under Section 69A. Without compelling counter-evidence from the assessee to challenge the findings, ITAT upheld the original assessments and summarily dismissed both appeals, affirming the tax department's conclusions regarding undisclosed income and improper purchase transactions.
In a tax dispute before ITAT involving search and survey operations by CGST authorities, the tribunal examined allegations of bogus purchases based on incriminating evidence discovered during investigations. The tribunal found substantial materials supporting tax authorities' disallowances under Section 69A. Without compelling counter-evidence from the assessee to challenge the findings, ITAT upheld the original assessments and summarily dismissed both appeals, affirming the tax department's conclusions regarding undisclosed income and improper purchase transactions.
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