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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Revision u/s 263 - Transfer of land by wife to her husband - Nature of transaction - Sale or Gift - It is the case of the assessee that sale deed is nothing but gift deed intended to transfer the land as vouched by lack of consideration and in view of the intented circumstances. This fact was brought on record by way of oral evidence as well as circumstantial evidence. - AO also invoked Section 64 for clubbing of income and simultaneously exonerated the assessee from the liability of LTCG on notional consideration - Revision order quashed - AT
Revision u/s 263 - Transfer of land by wife to her husband - Nature of transaction - Sale or Gift - It is the case of the assessee that sale deed is nothing but gift deed intended to transfer the land as vouched by lack of consideration and in view of the intented circumstances. This fact was brought on record by way of oral evidence as well as circumstantial evidence. - AO also invoked Section 64 for clubbing of income and simultaneously exonerated the assessee from the liability of LTCG on notional consideration - Revision order quashed - AT
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