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...
Renewal of charitable registration under section 12A(1)(ac)(ii) had to be decided by the Commissioner of Income-tax (Exemptions), and transfer of PAN or assessment jurisdiction did not confer subject-matter jurisdiction on the Principal Commissioner (Central); the impugned rejection was therefore without jurisdiction. On merits, the renewal enquiry was confined to genuineness of activities and compliance with allied laws, and could not be expanded into cancellation-style allegations under section 12AB(4). Search-period material, minor irregularities, and Settlement Commission observations did not justify denial where education activity was otherwise accepted. The Tribunal directed renewal of registration and issue of the certificate.
Renewal of charitable registration under section 12A(1)(ac)(ii) had to be decided by the Commissioner of Income-tax (Exemptions), and transfer of PAN or assessment jurisdiction did not confer subject-matter jurisdiction on the Principal Commissioner (Central); the impugned rejection was therefore without jurisdiction. On merits, the renewal enquiry was confined to genuineness of activities and compliance with allied laws, and could not be expanded into cancellation-style allegations under section 12AB(4). Search-period material, minor irregularities, and Settlement Commission observations did not justify denial where education activity was otherwise accepted. The Tribunal directed renewal of registration and issue of the certificate.
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