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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Rental income earned by assessee should be assessed as income from house property, not business income. AO failed to highlight aspects indicating rental income was earned in organized manner or additional facilities provided apart from renting property. Service charges collected were statutory requirement. In previous years, rental income was accepted as house property income. Principle of consistency applies. AO's finding that rental income is business income vacated. AO directed to treat rental income as income from house property and determine taxable income accordingly. Assessee's appeal allowed.
Rental income earned by assessee should be assessed as income from house property, not business income. AO failed to highlight aspects indicating rental income was earned in organized manner or additional facilities provided apart from renting property. Service charges collected were statutory requirement. In previous years, rental income was accepted as house property income. Principle of consistency applies. AO's finding that rental income is business income vacated. AO directed to treat rental income as income from house property and determine taxable income accordingly. Assessee's appeal allowed.
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