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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LTCG - Exemption claimed u/s. 54F - Failure to deposited in capital gain deposit scheme - The appellant sold a property, deposited the sale proceeds in a capital gain account scheme, and intended to utilize the funds for the purchase or construction of a new property within the statutory period. However, the completion of construction was delayed beyond the prescribed time frame. The ITAT ruled in favor of the appellant, emphasizing that the utilization of funds from the capital gain account scheme for the new investment was not mandatory, and the appellant could use other available funds without affecting their claim for deduction.
LTCG - Exemption claimed u/s. 54F - Failure to deposited in capital gain deposit scheme - The appellant sold a property, deposited the sale proceeds in a capital gain account scheme, and intended to utilize the funds for the purchase or construction of a new property within the statutory period. However, the completion of construction was delayed beyond the prescribed time frame. The ITAT ruled in favor of the appellant, emphasizing that the utilization of funds from the capital gain account scheme for the new investment was not mandatory, and the appellant could use other available funds without affecting their claim for deduction.
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