Commercial vehicle depreciation, scientifically determined warranty provisions and exempt-income disallowances were resolved in favour of the taxpayer...
Inherited property sale proceeds require capital-gains treatment where ownership is supported by evidence, not suspicion or unverified signature doubt...
Cross-examination of retracted statements is essential where foundational evidence supports a benami allegation and documented funding explanations re...
Under Rule 10B, reasonably accurate adjustments may be made in TNMM where a difference materially distorts net profit margin; depreciation on in-house software was treated as requiring adjustment because it substantially affected the assessee's PLI and the benchmarking exercise, and recomputation was directed. The Tribunal also accepted an upper turnover filter for comparability, holding that companies with vastly higher turnover than the assessee were not meaningfully comparable and must be excluded. On functional dissimilarity, the Tribunal found the existing record insufficient for a final finding because relevant submissions had not been properly examined, and remitted the issue to the TPO for fresh consideration.
Under Rule 10B, reasonably accurate adjustments may be made in TNMM where a difference materially distorts net profit margin; depreciation on in-house software was treated as requiring adjustment because it substantially affected the assessee's PLI and the benchmarking exercise, and recomputation was directed. The Tribunal also accepted an upper turnover filter for comparability, holding that companies with vastly higher turnover than the assessee were not meaningfully comparable and must be excluded. On functional dissimilarity, the Tribunal found the existing record insufficient for a final finding because relevant submissions had not been properly examined, and remitted the issue to the TPO for fresh consideration.
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