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...
HC upholds conviction of the Respondent for charge under s.276B IT Act for failing to deposit TDS deducted during FY 2012-13, the trial court (ACMM) having found delays of 4-15 months proved by documentary evidence and not disputed. The court rejects the Respondent's s.278AA defence for reasonable cause, observing the onus to prove financial incapacity was not discharged: no corroborative witnesses or financial records were produced and a bare assertion in the s.313 statement was insufficient. The HC sets aside the ASJ's contrary order, affirms guilt, but modifies sentence - replacing the fine of Rs.25 lakh with admonition given deposit of tax with interest and ongoing liquidation.
HC upholds conviction of the Respondent for charge under s.276B IT Act for failing to deposit TDS deducted during FY 2012-13, the trial court (ACMM) having found delays of 4-15 months proved by documentary evidence and not disputed. The court rejects the Respondent's s.278AA defence for reasonable cause, observing the onus to prove financial incapacity was not discharged: no corroborative witnesses or financial records were produced and a bare assertion in the s.313 statement was insufficient. The HC sets aside the ASJ's contrary order, affirms guilt, but modifies sentence - replacing the fine of Rs.25 lakh with admonition given deposit of tax with interest and ongoing liquidation.
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