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 dispute regarding income from property, specifically addressing notional rental income for six unsold residential units. The tribunal examined prior assessments from 2012-13 and 2014-15, where similar factual circumstances led to conflicting outcomes. Applying consistent judicial reasoning from coordinate bench precedents, the tribunal set aside the assessing officer's addition of notional rental income. The tribunal determined that the proposed taxation on unsold properties was unwarranted, effectively deleting the contested income addition. Consequently, the assessee's appeal was allowed, thereby eliminating the proposed tax liability related to the unoccupied residential units.
ITAT adjudicated a dispute regarding income from property, specifically addressing notional rental income for six unsold residential units. The tribunal examined prior assessments from 2012-13 and 2014-15, where similar factual circumstances led to conflicting outcomes. Applying consistent judicial reasoning from coordinate bench precedents, the tribunal set aside the assessing officer's addition of notional rental income. The tribunal determined that the proposed taxation on unsold properties was unwarranted, effectively deleting the contested income addition. Consequently, the assessee's appeal was allowed, thereby eliminating the proposed tax liability related to the unoccupied residential units.
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