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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Regarding long-term capital gain determination, indexed cost of acquisition claimed by assessee at Rs. 45 lakhs for property valued over Rs. 45 lakhs, evidenced by payment through cheques, held acceptable for indexation benefit computation. Addition of Rs. 33,73,120 towards long-term capital gain directed to be deleted. Concerning denial of benefit of carry forward of capital loss, despite setting off long-term capital gain against long-term capital loss as per DRP direction, assessee held entitled to avail carry forward of remaining long-term capital loss. Assessing Officer directed to verify factually and allow carry forward of long-term capital loss claimed.
Regarding long-term capital gain determination, indexed cost of acquisition claimed by assessee at Rs. 45 lakhs for property valued over Rs. 45 lakhs, evidenced by payment through cheques, held acceptable for indexation benefit computation. Addition of Rs. 33,73,120 towards long-term capital gain directed to be deleted. Concerning denial of benefit of carry forward of capital loss, despite setting off long-term capital gain against long-term capital loss as per DRP direction, assessee held entitled to avail carry forward of remaining long-term capital loss. Assessing Officer directed to verify factually and allow carry forward of long-term capital loss claimed.
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