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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Nature of land sold - agricultural land - distance between two physical points on the surface of earth from local limits of the Municipality - Distance Measurement - The Tribunal observed that the adjudication by the CIT(A) lacked thoroughness as it favored the evidence relied upon by the assessee without adequately addressing the evidence presented by the Revenue. Both parties relied on satellite mapping technology to determine the distance, with conflicting results. The Tribunal emphasized the importance of reconciling the differences in measurements and noted the lack of contemporaneous evidence provided by the assessee during the assessment proceedings. The Tribunal concluded that the matter required a precise measurement and instructed the Assessing Officer (AO) to obtain coordinates from both the subject land and the local limits of the Municipality as of the transfer date.
Nature of land sold - agricultural land - distance between two physical points on the surface of earth from local limits of the Municipality - Distance Measurement - The Tribunal observed that the adjudication by the CIT(A) lacked thoroughness as it favored the evidence relied upon by the assessee without adequately addressing the evidence presented by the Revenue. Both parties relied on satellite mapping technology to determine the distance, with conflicting results. The Tribunal emphasized the importance of reconciling the differences in measurements and noted the lack of contemporaneous evidence provided by the assessee during the assessment proceedings. The Tribunal concluded that the matter required a precise measurement and instructed the Assessing Officer (AO) to obtain coordinates from both the subject land and the local limits of the Municipality as of the transfer date.
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