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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Determination of long term capital gain u/s 50C - The Tribunal observed that the part payment of consideration was received by the assessee prior to the execution of the agreement to sale. Furthermore, the sale consideration declared by the assessee was significantly higher than the prevailing jantri rate at the time of the agreement. Therefore, the Tribunal held that the assessee was entitled to the benefit of the first and second provisos to Section 50C.
Determination of long term capital gain u/s 50C - The Tribunal observed that the part payment of consideration was received by the assessee prior to the execution of the agreement to sale. Furthermore, the sale consideration declared by the assessee was significantly higher than the prevailing jantri rate at the time of the agreement. Therefore, the Tribunal held that the assessee was entitled to the benefit of the first and second provisos to Section 50C.
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