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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Computation of Capital gain - Section 50C applicability - first proviso to Section 50C of the Act, is applicable retrospectively. It does not create any new right between the parties. It simply clarifies the existing position of law. - CIT(A) after referring to first proviso to Section 50C of the Act, directed the Assessing Officer to adopt the guideline value as on 04.08.2012, being the date of agreement and there after compute the assessee’s capital gain. Therefore the Revenue cannot have any grievance in the decision of the CIT(A).
Computation of Capital gain - Section 50C applicability - first proviso to Section 50C of the Act, is applicable retrospectively. It does not create any new right between the parties. It simply clarifies the existing position of law. - CIT(A) after referring to first proviso to Section 50C of the Act, directed the Assessing Officer to adopt the guideline value as on 04.08.2012, being the date of agreement and there after compute the assessee’s capital gain. Therefore the Revenue cannot have any grievance in the decision of the CIT(A).
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