Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
Automated Free Sale and Commerce Certificates enable paperless processing while retaining risk-based manual verification for selected exporter applica...
Page of 4830
Press 'Enter' after typing page number.
161 to 180 of 96587 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
The ITAT, an Appellate Tribunal, addressed two key issues. Firstly, regarding the difference in sale consideration and stamp duty for 3 flats sold by the assessee, it was held that the addition made was not sustainable as the statute allows a leverage of 10%, while the difference in property value was only 2.5%. Therefore, the addition was deleted. Secondly, concerning the inclusion of the entire sale value of two flats in the next financial year, it was emphasized that tax neutrality is crucial to avoid double taxation and ensure fair taxation. As the income was already included in the next year's accounts, the addition during the current year was deemed neutral. Following the principle of neutrality, the AO was directed to delete the alleged addition, as applying the analogy established in a Supreme Court case, no double addition should be made. The appeal of the assessee was allowed.
The ITAT, an Appellate Tribunal, addressed two key issues. Firstly, regarding the difference in sale consideration and stamp duty for 3 flats sold by the assessee, it was held that the addition made was not sustainable as the statute allows a leverage of 10%, while the difference in property value was only 2.5%. Therefore, the addition was deleted. Secondly, concerning the inclusion of the entire sale value of two flats in the next financial year, it was emphasized that tax neutrality is crucial to avoid double taxation and ensure fair taxation. As the income was already included in the next year's accounts, the addition during the current year was deemed neutral. Following the principle of neutrality, the AO was directed to delete the alleged addition, as applying the analogy established in a Supreme Court case, no double addition should be made. The appeal of the assessee was allowed.
Note: It is a system-generated summary and is for quick reference only.