Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
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...
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One-time clubhouse charges, corpus fund contributions and municipal taxes paid to a developer during acquisition may form part of a residential property's cost of acquisition where they have a direct and proximate nexus with obtaining the asset and its attendant rights. Cost is not limited to the basic sale price; the purpose of each payment, its commercial context and supporting evidence determine its treatment. Clubhouse charges linked to the flat, non-refundable corpus contributions for enduring common infrastructure, and municipal taxes collected during construction may qualify where they are not recurring post-acquisition liabilities. Such amounts are includible in the relevant cost components for capital-gains computation, with consequential indexation where otherwise admissible.
One-time clubhouse charges, corpus fund contributions and municipal taxes paid to a developer during acquisition may form part of a residential property's cost of acquisition where they have a direct and proximate nexus with obtaining the asset and its attendant rights. Cost is not limited to the basic sale price; the purpose of each payment, its commercial context and supporting evidence determine its treatment. Clubhouse charges linked to the flat, non-refundable corpus contributions for enduring common infrastructure, and municipal taxes collected during construction may qualify where they are not recurring post-acquisition liabilities. Such amounts are includible in the relevant cost components for capital-gains computation, with consequential indexation where otherwise admissible.
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