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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Disallowance of exemption claimed u/s 54F - nature of the property as residential in nature - It does not make difference whether the property has been shown as residential house on the record of the government authority but actual user thereof by the assessee will be considered while adjudicating upon the eligibility of deduction under sec. 54F Claimed by the assessee. In the present case, for denial of the claimed deduction under sec. 54F AO should not have considered the property as residential on the basis of municipal record ignoring the actual user thereof, as held in the above cited decisions. - AT
Disallowance of exemption claimed u/s 54F - nature of the property as residential in nature - It does not make difference whether the property has been shown as residential house on the record of the government authority but actual user thereof by the assessee will be considered while adjudicating upon the eligibility of deduction under sec. 54F Claimed by the assessee. In the present case, for denial of the claimed deduction under sec. 54F AO should not have considered the property as residential on the basis of municipal record ignoring the actual user thereof, as held in the above cited decisions. - AT
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