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...
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...
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Capital Gain - addition u/s 50C - third proviso to Section 50C inserted w.e.f 1-4-2019 - benefit of variation of 5% - even when the statute does not specifically state so the insertion of third proviso to Section 50C is declaratory and curative in nature, can only be treated as retrospective and effective from the date related statutory provisions was introduced i.e. from 1st April 2003 - retrospective
Capital Gain - addition u/s 50C - third proviso to Section 50C inserted w.e.f 1-4-2019 - benefit of variation of 5% - even when the statute does not specifically state so the insertion of third proviso to Section 50C is declaratory and curative in nature, can only be treated as retrospective and effective from the date related statutory provisions was introduced i.e. from 1st April 2003 - retrospective
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