Charitable sports promotion: sponsorship receipts alone did not defeat registration where funds supported tournaments and player development activitie...
Overdue associated-enterprise receivables: debt-free status defeated notional-interest adjustment, while employee stock-option costs qualified as busi...
Retrospective assessment-limitation amendments validate final orders while contemporaneous segment data governs transfer-pricing comparability and tol...
Transfer pricing adjustments must track international transactions, while unsupported AMP adjustments and unsuitable manufacturing comparables require...
Transfer-pricing adjustments must reflect functional comparability, working-capital effects, and avoid duplicating interest on associated-enterprise r...
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Section 50's deeming fiction treats gains on transfer of depreciable assets as short-term capital gains only for capital-gains computation. It does not exclude commercial profit credited to the Profit and Loss Account from book profit used to determine the ceiling on working partners' remuneration. Explanation 3 to section 40(b) starts with net profit in the Profit and Loss Account, subject to Chapter IV-D adjustments and add-back of remuneration already deducted, rather than excluding receipts taxable under another income head. Profit from sale of depreciable shop premises therefore remained in book profit, making the claimed partners' remuneration within the statutory ceiling and requiring deletion of the disallowance.
Section 50's deeming fiction treats gains on transfer of depreciable assets as short-term capital gains only for capital-gains computation. It does not exclude commercial profit credited to the Profit and Loss Account from book profit used to determine the ceiling on working partners' remuneration. Explanation 3 to section 40(b) starts with net profit in the Profit and Loss Account, subject to Chapter IV-D adjustments and add-back of remuneration already deducted, rather than excluding receipts taxable under another income head. Profit from sale of depreciable shop premises therefore remained in book profit, making the claimed partners' remuneration within the statutory ceiling and requiring deletion of the disallowance.
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