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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Nature of income - Award received as settlement through an arbitration award - Amount received for withdrawal of cases against the erstwhile partners and partnership firm - To be treated as income from business under section 28(iv) or “Income from other sources” under section 56(1) - the arbitration award is taxable as “Income from other sources” under section 56(1) of the Act, the issue is squarely covered insofar as the present appeal is concerned and nothing survives to be decided. - AT
Nature of income - Award received as settlement through an arbitration award - Amount received for withdrawal of cases against the erstwhile partners and partnership firm - To be treated as income from business under section 28(iv) or “Income from other sources” under section 56(1) - the arbitration award is taxable as “Income from other sources” under section 56(1) of the Act, the issue is squarely covered insofar as the present appeal is concerned and nothing survives to be decided. - AT
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