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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Deduction u/s 54F - delay in delivery of possession of the property - investment of the entire capital gains for construction of a residential house within the stipulated period alone is relevant, and delivery of possession by the builder/promoter of the assessee of the said residential house cannot be a ground to deny the assessee deduction under Section 54F of the Act, for the reason that the assessee has no control over the actions of the builder/promoter and he cannot be punished for the delay on the part of the builder/promoter in delivering possession.
Deduction u/s 54F - delay in delivery of possession of the property - investment of the entire capital gains for construction of a residential house within the stipulated period alone is relevant, and delivery of possession by the builder/promoter of the assessee of the said residential house cannot be a ground to deny the assessee deduction under Section 54F of the Act, for the reason that the assessee has no control over the actions of the builder/promoter and he cannot be punished for the delay on the part of the builder/promoter in delivering possession.
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