Development agreements require legal possession or effective enjoyment for capital gains transfer; permissive possession and deferred consideration de...
Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
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MAT computation u/s 115JB - Adjustment for computation of book profits u/s. 115JB on the ground that expenses are unascertained liability. - The Tribunal addressed each provision made by the assessee (for HD commission, ex gratia and bonus, gratuity to HD canvassers, and gratuity), analyzing whether they constituted ascertained or contingent liabilities. It referenced judicial precedents to allow the assessee's claims, emphasizing the principle that provisions based on actuarial valuations are considered ascertained liabilities.
MAT computation u/s 115JB - Adjustment for computation of book profits u/s. 115JB on the ground that expenses are unascertained liability. - The Tribunal addressed each provision made by the assessee (for HD commission, ex gratia and bonus, gratuity to HD canvassers, and gratuity), analyzing whether they constituted ascertained or contingent liabilities. It referenced judicial precedents to allow the assessee's claims, emphasizing the principle that provisions based on actuarial valuations are considered ascertained liabilities.
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