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 adjudicated a tax dispute involving alleged bogus purchases. The appellate tribunal recognized the assessee's declaration of gross profit rates of 4.8522% and 7.6318% in financial years 2009-10 and 2010-11, respectively. Upon reviewing the auditor's report, the tribunal found that the lower authority (CIT(A)) erroneously applied an 8% gross profit rate without granting credit for previously declared rates. To prevent double taxation, the tribunal directed the Assessing Officer to provide relief by considering the gross profit rates already reported in the Trading Account, with the revenue department concurring with this limited relief.
ITAT adjudicated a tax dispute involving alleged bogus purchases. The appellate tribunal recognized the assessee's declaration of gross profit rates of 4.8522% and 7.6318% in financial years 2009-10 and 2010-11, respectively. Upon reviewing the auditor's report, the tribunal found that the lower authority (CIT(A)) erroneously applied an 8% gross profit rate without granting credit for previously declared rates. To prevent double taxation, the tribunal directed the Assessing Officer to provide relief by considering the gross profit rates already reported in the Trading Account, with the revenue department concurring with this limited relief.
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