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 receipt - interest received by the assessee u/s 28 and 34 of the Land Acquisition Act, 1894 - The Delhi High Court, in a case concerning the taxability of interest earned on compensation or enhanced compensation under the Land Acquisition Act, 1894, examined the provisions of the Income Tax Act, 1961, and relevant judicial precedents. - The court also examines the applicability of Section 145-B of the Income Tax Act, which deems interest on compensation or enhanced compensation as income of the year in which it is received, subject to tax. - Considering the legislative intent behind the 2009 amendment and the clear language of the statute, the court concludes that interest, whether on compensation or enhanced compensation, should be considered income from other sources and is subject to tax.
Characterization of receipt - interest received by the assessee u/s 28 and 34 of the Land Acquisition Act, 1894 - The Delhi High Court, in a case concerning the taxability of interest earned on compensation or enhanced compensation under the Land Acquisition Act, 1894, examined the provisions of the Income Tax Act, 1961, and relevant judicial precedents. - The court also examines the applicability of Section 145-B of the Income Tax Act, which deems interest on compensation or enhanced compensation as income of the year in which it is received, subject to tax. - Considering the legislative intent behind the 2009 amendment and the clear language of the statute, the court concludes that interest, whether on compensation or enhanced compensation, should be considered income from other sources and is subject to tax.
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