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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Short Term capital Gains - Transfer / Conversion of Redeemable Cumulative Convertible Preference Share and Fully Compulsory Convertible Preference Shares to equity shares - In the present case, it is to be appreciated that the conversion of preference shares into equity shares is in the hands of the shareholder. - Thus, gain, if any, arising from such a conversion will only be taxable in the hands of the shareholder - Additions deleted - AT
Short Term capital Gains - Transfer / Conversion of Redeemable Cumulative Convertible Preference Share and Fully Compulsory Convertible Preference Shares to equity shares - In the present case, it is to be appreciated that the conversion of preference shares into equity shares is in the hands of the shareholder. - Thus, gain, if any, arising from such a conversion will only be taxable in the hands of the shareholder - Additions deleted - AT
Note: It is a system-generated summary and is for quick reference only.
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