Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
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...
Redevelopment hardship compensation received as a predetermined lump-sum for shifting, re-shifting, demolition-related inconvenience and shared common areas was held to be a capital receipt, not consideration for transfer of property rights, so the addition was deleted. The first appellate authority's direction to compute capital gain on the additional 56% carpet area was treated as an enhancement of income; because no prior show-cause notice or opportunity under section 251(2) was shown, that enhancement was set aside and the issue was remitted for fresh consideration after hearing the assessee.
Redevelopment hardship compensation received as a predetermined lump-sum for shifting, re-shifting, demolition-related inconvenience and shared common areas was held to be a capital receipt, not consideration for transfer of property rights, so the addition was deleted. The first appellate authority's direction to compute capital gain on the additional 56% carpet area was treated as an enhancement of income; because no prior show-cause notice or opportunity under section 251(2) was shown, that enhancement was set aside and the issue was remitted for fresh consideration after hearing the assessee.
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