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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Capital Gain - Transfer u/s 2(47)(v) - assessment year - AO himself has given credit for the amount of capital gains declared for the assessment year 2013-14, while computing capital gains in the impugned assessment year. Once the AO came to the conclusion that the assessee has offered capital gains in the earlier assessment year, then there is no reason for the AO to compute capital gains on transfer of very same asset in the impugned assessment year, because transfer will not take place in two assessment years. - AT
Capital Gain - Transfer u/s 2(47)(v) - assessment year - AO himself has given credit for the amount of capital gains declared for the assessment year 2013-14, while computing capital gains in the impugned assessment year. Once the AO came to the conclusion that the assessee has offered capital gains in the earlier assessment year, then there is no reason for the AO to compute capital gains on transfer of very same asset in the impugned assessment year, because transfer will not take place in two assessment years. - AT
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