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...
Receipt of a new residential flat in exchange for surrender of an old flat under a redevelopment arrangement was held not to be receipt of immovable property for inadequate consideration within section 56(2)(x). The Tribunal, relying on its earlier decision in Anil Dattaram Pitale v. ITO, found that the transaction was an exchange linked to redevelopment rather than a taxable transfer attracting deemed income. The addition made under section 56(2)(x) was therefore deleted in full, and the appeal was allowed on merits.
Receipt of a new residential flat in exchange for surrender of an old flat under a redevelopment arrangement was held not to be receipt of immovable property for inadequate consideration within section 56(2)(x). The Tribunal, relying on its earlier decision in Anil Dattaram Pitale v. ITO, found that the transaction was an exchange linked to redevelopment rather than a taxable transfer attracting deemed income. The addition made under section 56(2)(x) was therefore deleted in full, and the appeal was allowed on merits.
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