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 - Determination of Fair Market Value (FMV) - The Assessing Officer and the Commissioner of Income Tax (Appeals) accepted the fair market value of the property as on April 1, 1981, as calculated by the registered valuer. However, they failed to apply indexation benefits to the cost of acquisition while determining long-term capital gain. The Tribunal observed that the indexed cost of acquisition should have been considered, which would have resulted in long-term capital loss, as it exceeded the sale consideration.
LTCG - Determination of Fair Market Value (FMV) - The Assessing Officer and the Commissioner of Income Tax (Appeals) accepted the fair market value of the property as on April 1, 1981, as calculated by the registered valuer. However, they failed to apply indexation benefits to the cost of acquisition while determining long-term capital gain. The Tribunal observed that the indexed cost of acquisition should have been considered, which would have resulted in long-term capital loss, as it exceeded the sale consideration.
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