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 - Denial of benefit of 1st proviso to section 50C(1) which allows the consideration value fixed in the agreement to be considered instead of the stamp valuation for the computation of full value of consideration for transfer. - Proof of agreement prior to application of section 50C - The Tribunal noted that a part of the consideration must be received through specific banking channels before the agreement date. As the payment did not meet this requirement, the benefit of the first proviso was denied. - The ITAT also dismissed the contention regarding the denial of deduction under section 54B, upholding the lower authorities' decision.
Capital gain - Denial of benefit of 1st proviso to section 50C(1) which allows the consideration value fixed in the agreement to be considered instead of the stamp valuation for the computation of full value of consideration for transfer. - Proof of agreement prior to application of section 50C - The Tribunal noted that a part of the consideration must be received through specific banking channels before the agreement date. As the payment did not meet this requirement, the benefit of the first proviso was denied. - The ITAT also dismissed the contention regarding the denial of deduction under section 54B, upholding the lower authorities' decision.
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