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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Characterization of income - income arising from sub-licensing of shops and establishment along with the various services - ITAT, after referring to section 27 (iiib) of the Income Tax Act defining the term “deemed owner” and Section 269UA(f) of the Act defining the word “transfer”; held that the income derived by the assessee is “Income from House Property.” - the ITAT has committed a manifest error of law to ignore the object and business activity of the appellant assessee company, and misunderstood the nature of transaction of sub-license. - HC
Characterization of income - income arising from sub-licensing of shops and establishment along with the various services - ITAT, after referring to section 27 (iiib) of the Income Tax Act defining the term “deemed owner” and Section 269UA(f) of the Act defining the word “transfer”; held that the income derived by the assessee is “Income from House Property.” - the ITAT has committed a manifest error of law to ignore the object and business activity of the appellant assessee company, and misunderstood the nature of transaction of sub-license. - HC
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