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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The case involved determining whether gains from the sale of shares allotted in an IPO should be classified as Short-Term Capital Gains (STCG) or business income. The principle of consistency was emphasized, with CBDT Circular stating that if shares are treated as investments, income from their transfer should be considered capital gains. The CBDT Circular aimed to reduce litigation and uncertainty. The Revenue's change in treatment without valid reason was deemed incorrect. Court precedents supported treating such gains as capital gains when shares were held as investments. The Revenue's classification of the gains as business income was overturned, and the gains were treated as STCG, following the principle of consistency. The appeal by the assessee was allowed.
The case involved determining whether gains from the sale of shares allotted in an IPO should be classified as Short-Term Capital Gains (STCG) or business income. The principle of consistency was emphasized, with CBDT Circular stating that if shares are treated as investments, income from their transfer should be considered capital gains. The CBDT Circular aimed to reduce litigation and uncertainty. The Revenue's change in treatment without valid reason was deemed incorrect. Court precedents supported treating such gains as capital gains when shares were held as investments. The Revenue's classification of the gains as business income was overturned, and the gains were treated as STCG, following the principle of consistency. The appeal by the assessee was allowed.
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