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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Assessment of capital gains on sale of agricultural land or landed property - the assessee’s case clearly falls under clause (b)(ii) to provisions of section 2(14)(iii) reason being assessee’s land is outside Hindupur Municipal limits at a distance of 4 kms measured aerially and as per provisional report of Census of India, population of Hindupur Municipality in 2011 is 151677. Hence, the AO has rightly charged assessee’s land to capital gain tax and the CIT(A) has rightly affirmed the same. - AT
Assessment of capital gains on sale of agricultural land or landed property - the assessee’s case clearly falls under clause (b)(ii) to provisions of section 2(14)(iii) reason being assessee’s land is outside Hindupur Municipal limits at a distance of 4 kms measured aerially and as per provisional report of Census of India, population of Hindupur Municipality in 2011 is 151677. Hence, the AO has rightly charged assessee’s land to capital gain tax and the CIT(A) has rightly affirmed the same. - AT
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