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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Addition to income from capital gains - Nature of land sold - Anyhow, to meet the ends of natural justice, we direct the assessee to file complete sale deeds of the properties sold, and other original relevant revenue records for verification of the properties as agricultural land or not by the Assessing Officer. The Assessing Officer is accordingly directed to verify complete documentary evidences for the claim of the assessee that the lands sold by it are agricultural land and it had been used for agricultural cultivation and in case, if the assessee fails to furnish complete documentary evidences for verification, the assessment already completed and confirmed the ld. CIT(A) stands sustained. - AT
Addition to income from capital gains - Nature of land sold - Anyhow, to meet the ends of natural justice, we direct the assessee to file complete sale deeds of the properties sold, and other original relevant revenue records for verification of the properties as agricultural land or not by the Assessing Officer. The Assessing Officer is accordingly directed to verify complete documentary evidences for the claim of the assessee that the lands sold by it are agricultural land and it had been used for agricultural cultivation and in case, if the assessee fails to furnish complete documentary evidences for verification, the assessment already completed and confirmed the ld. CIT(A) stands sustained. - AT
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