Receipt of immovable property requires actual possession or enjoyment; redevelopment allotments exchanged for tenancy rights fall outside deemed incom...
Section 80P deduction covers Souharda credit societies, including qualifying surplus-deposit interest, subject to member KYC verification for cash dep...
Transfer-pricing benchmarking and capital-receipt principles sustained taxpayer relief, while unsupported property-advance write-offs remained disallo...
Transfer-pricing method selection between the Comparable Uncontrolled Price method and the Transactional Net Margin Method is primarily a fact-based benchmarking issue. The Tribunal's acceptance of TNMM as the most appropriate method was treated as sustainable where it was not perverse or contrary to the record. Mere disagreement over the appropriate method does not create a substantial question of law under section 260A unless the selected method contravenes prescribed rules. Differences between associated-enterprise and non-associated-enterprise transactions were also considered within the benchmarking analysis. The tax appeals were dismissed because the transfer-pricing questions raised no substantial question of law.
Transfer-pricing method selection between the Comparable Uncontrolled Price method and the Transactional Net Margin Method is primarily a fact-based benchmarking issue. The Tribunal's acceptance of TNMM as the most appropriate method was treated as sustainable where it was not perverse or contrary to the record. Mere disagreement over the appropriate method does not create a substantial question of law under section 260A unless the selected method contravenes prescribed rules. Differences between associated-enterprise and non-associated-enterprise transactions were also considered within the benchmarking analysis. The tax appeals were dismissed because the transfer-pricing questions raised no substantial question of law.
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