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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LTCG - year of taxability on transfer of development rights in a plot of land - Year of Chargeability - CIT(A) held that capital gain is taxable in AY 2012-13 rather than in AY 2009-10 - the capital asset of the assessee cannot be treated as transferred u/s 2(47)(4) of the Act read with section 53A of the Transfer of Property Act in assessment year 2009-10. We do not find any error in the finding of the Ld. CIT(A) on the issue in dispute - AT
LTCG - year of taxability on transfer of development rights in a plot of land - Year of Chargeability - CIT(A) held that capital gain is taxable in AY 2012-13 rather than in AY 2009-10 - the capital asset of the assessee cannot be treated as transferred u/s 2(47)(4) of the Act read with section 53A of the Transfer of Property Act in assessment year 2009-10. We do not find any error in the finding of the Ld. CIT(A) on the issue in dispute - AT
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