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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Taxation on gains arising out of compulsory acquisitions - Admission of Additional Grounds - the Appellate Tribunal analyzed the legislative timeline and relevant provisions, particularly focusing on the Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013 (RFCTLARR Act) and its applicability to state land acquisition acts. They concluded that the compensation received by the assessee fell under a state act and not under RFCTLARR Act. Therefore, the benefit of exemption from taxation could not be extended to the assessee. - The Appellate Tribunal admitted the additional grounds raised by the appellant, considering them as legal grounds not requiring appreciation of new facts. They acknowledged that these grounds were fundamental to the assessment and proceeded to address them first.
Taxation on gains arising out of compulsory acquisitions - Admission of Additional Grounds - the Appellate Tribunal analyzed the legislative timeline and relevant provisions, particularly focusing on the Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013 (RFCTLARR Act) and its applicability to state land acquisition acts. They concluded that the compensation received by the assessee fell under a state act and not under RFCTLARR Act. Therefore, the benefit of exemption from taxation could not be extended to the assessee. - The Appellate Tribunal admitted the additional grounds raised by the appellant, considering them as legal grounds not requiring appreciation of new facts. They acknowledged that these grounds were fundamental to the assessment and proceeded to address them first.
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