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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Setting off the long term capital loss arising on sale of shares not subject to STT against long term capital gain arising from sale of Shares subjected to STT exempt from tax under section 10(38) - At this stage we would also like to make an additional mention that even if assume, without accepting, that the revenue’s contention is correct in setting off losses against exempt income [long term capital gain u/s 10(38)], there would be an absurd outcome. - the lower authorities are not justified in setting off losses against the exempted long-term capital gain thereby reducing the quantum of carry forward of losses claimed by the assessee - AT
Setting off the long term capital loss arising on sale of shares not subject to STT against long term capital gain arising from sale of Shares subjected to STT exempt from tax under section 10(38) - At this stage we would also like to make an additional mention that even if assume, without accepting, that the revenue’s contention is correct in setting off losses against exempt income [long term capital gain u/s 10(38)], there would be an absurd outcome. - the lower authorities are not justified in setting off losses against the exempted long-term capital gain thereby reducing the quantum of carry forward of losses claimed by the assessee - AT
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