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...
Reopening of assessment was upheld where impounded loose papers and a purchaser's admission provided prima facie material of undisclosed cash consideration, corroborated by matching cheque entries and registered sale deeds; failure of the assessee to specifically seek cross examination at reassessment foreclosed a later natural justice challenge. The impounded documents were treated as reliable corroborative evidence rather than vague papers, and the existence of substantial disparity between recorded and apparent market value reinforced inference of on money. On these grounds the assessing officer's addition as unaccounted sale consideration was held justified and the claim against reassessment failed.
Reopening of assessment was upheld where impounded loose papers and a purchaser's admission provided prima facie material of undisclosed cash consideration, corroborated by matching cheque entries and registered sale deeds; failure of the assessee to specifically seek cross examination at reassessment foreclosed a later natural justice challenge. The impounded documents were treated as reliable corroborative evidence rather than vague papers, and the existence of substantial disparity between recorded and apparent market value reinforced inference of on money. On these grounds the assessing officer's addition as unaccounted sale consideration was held justified and the claim against reassessment failed.
Note: It is a system-generated summary and is for quick reference only.