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...
Depreciation was denied on conversion charges paid for change of land use because the expenditure related to land owned by another entity and did not create any independent depreciable asset in the assessee's hands; Explanation 1 to section 32 was held confined to capital expenditure on a building or work connected with a building, not land or rights in land. The alternative claim for revenue deduction and the related interest claim also failed because the assessee did not own the underlying asset and the business-purpose nexus required for section 36(1)(iii) was not established. Penalty was deleted under section 271(1)(c) since the claim was fully disclosed and debatable, with no concealment or inaccurate particulars.
Depreciation was denied on conversion charges paid for change of land use because the expenditure related to land owned by another entity and did not create any independent depreciable asset in the assessee's hands; Explanation 1 to section 32 was held confined to capital expenditure on a building or work connected with a building, not land or rights in land. The alternative claim for revenue deduction and the related interest claim also failed because the assessee did not own the underlying asset and the business-purpose nexus required for section 36(1)(iii) was not established. Penalty was deleted under section 271(1)(c) since the claim was fully disclosed and debatable, with no concealment or inaccurate particulars.
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