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...
Rectification of an assessment order extinguished the earlier addition made for share premium, merging the rectified order with the original assessment and preventing appellate re-adjudication; consequently the deletion effected by the assessing officer under rectification stands effective. Separately, where share subscribers were non-residents and no evidence supported domestic place of effective management, the valuation provision for share premium did not apply to shares issued to non-resident subscribers, so the addition was unsustainable on merits and deleted.
Rectification of an assessment order extinguished the earlier addition made for share premium, merging the rectified order with the original assessment and preventing appellate re-adjudication; consequently the deletion effected by the assessing officer under rectification stands effective. Separately, where share subscribers were non-residents and no evidence supported domestic place of effective management, the valuation provision for share premium did not apply to shares issued to non-resident subscribers, so the addition was unsustainable on merits and deleted.
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