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...
Capital gain computation under a joint development agreement was considered with two principal issues: whether deduction for indexed cost of acquisition of land is allowable where land rights were exchanged for constructed area, and whether deduction for cost of construction is allowable though no monetary investment was made by the assessee. The tribunal applied the rule that expenditure wholly and exclusively incurred in connection with transfer and cost of acquisition and improvement must be allowed, concluding the assessee retained compensable rights and was entitled in principle to deductions for indexed acquisition and construction costs; both issues were remitted to the AO for factual verification and quantification with admission of additional evidence.
Capital gain computation under a joint development agreement was considered with two principal issues: whether deduction for indexed cost of acquisition of land is allowable where land rights were exchanged for constructed area, and whether deduction for cost of construction is allowable though no monetary investment was made by the assessee. The tribunal applied the rule that expenditure wholly and exclusively incurred in connection with transfer and cost of acquisition and improvement must be allowed, concluding the assessee retained compensable rights and was entitled in principle to deductions for indexed acquisition and construction costs; both issues were remitted to the AO for factual verification and quantification with admission of additional evidence.
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