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...
Business expenditure claims for shortages and quality cuts were sent back for fresh verification because the lower authorities had rejected them for want of complete supporting evidence, while the Tribunal found no corroboration for the assumption that the goods remained in closing stock and noted that additional material had not yet been examined. The transfer pricing adjustment under the CUP method was also remanded because a disputed credit note appeared to involve only a clerical date error, and the revised arm's length computation with discounts and credit notes required verification. The omitted TDS credit was ordered to be granted because it had been acknowledged in the draft computation and was not denied by any DRP direction.
Business expenditure claims for shortages and quality cuts were sent back for fresh verification because the lower authorities had rejected them for want of complete supporting evidence, while the Tribunal found no corroboration for the assumption that the goods remained in closing stock and noted that additional material had not yet been examined. The transfer pricing adjustment under the CUP method was also remanded because a disputed credit note appeared to involve only a clerical date error, and the revised arm's length computation with discounts and credit notes required verification. The omitted TDS credit was ordered to be granted because it had been acknowledged in the draft computation and was not denied by any DRP direction.
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