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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Reopening of assessment u/s 147 - undisclosed capital gain - a right person is liable to pay tax on his income and no option is available to tax income in the hands of person other than one in whose hands it is taxable. - Income Tax is leviable only on the real income which the assessee has proved beyond doubt that assessee has received only 25% of the sale consideration - AT
Reopening of assessment u/s 147 - undisclosed capital gain - a right person is liable to pay tax on his income and no option is available to tax income in the hands of person other than one in whose hands it is taxable. - Income Tax is leviable only on the real income which the assessee has proved beyond doubt that assessee has received only 25% of the sale consideration - AT
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