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 as short term capital gain by invoking the provisions of section 50C - difference between the declared sale consideration and the market value is within the range of 5% - the benefit provided under the third proviso to section 50C(1) of the Act, should be extended to the assessee, as, ultimately the value determined by the Stamp Valuation Authority has been substituted by DVO's valuation in terms of sub-section (3) of section 50C of the Act. - AT
Addition as short term capital gain by invoking the provisions of section 50C - difference between the declared sale consideration and the market value is within the range of 5% - the benefit provided under the third proviso to section 50C(1) of the Act, should be extended to the assessee, as, ultimately the value determined by the Stamp Valuation Authority has been substituted by DVO's valuation in terms of sub-section (3) of section 50C of the Act. - AT
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