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...
Amendment to accumulation rules by Finance Act, 2022 prescribes utilisation of accumulated charitable funds within five years of accumulation; however, the amended provisions operate prospectively and do not curtail pre-existing six-year windows for accumulations arising before 1 April 2022. The tribunal applied the doctrine of impossibility to hold that income accumulated in financial year 201617 remained governed by the earlier six-year timeframe, precluding disallowance for the impugned assessment year. The assessees appeal was allowed and fresh accumulations from 1 April 2022 are subject to the new five-year requirement.
Amendment to accumulation rules by Finance Act, 2022 prescribes utilisation of accumulated charitable funds within five years of accumulation; however, the amended provisions operate prospectively and do not curtail pre-existing six-year windows for accumulations arising before 1 April 2022. The tribunal applied the doctrine of impossibility to hold that income accumulated in financial year 201617 remained governed by the earlier six-year timeframe, precluding disallowance for the impugned assessment year. The assessees appeal was allowed and fresh accumulations from 1 April 2022 are subject to the new five-year requirement.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4830 
Join Channel 
