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 pertains to the correct head of income for rental income receipts, whether assessable under 'Income From House Property' or 'Income from Business'. The key points are: The assessee's sole business was leasing properties, without any construction projects or major sales since incorporation. The Assessing Officer (AO) erroneously presumed that no prudent person would wait for over 10-20 years after receiving twice the cost of the building. The AO's assumption that the absence of legal proceedings by intending purchasers impacts tax levy is unfounded. The First Appellate Authority rightly treated the income as business income, given the assessee's sole business of renting buildings. Based on the AO's factual findings, the income cannot be treated as 'Income from House Property'. The High Court ruled in favor of the assessee, aligning with the precedents in Rayala Corporation and Chennai Properties cases.
The case pertains to the correct head of income for rental income receipts, whether assessable under 'Income From House Property' or 'Income from Business'. The key points are: The assessee's sole business was leasing properties, without any construction projects or major sales since incorporation. The Assessing Officer (AO) erroneously presumed that no prudent person would wait for over 10-20 years after receiving twice the cost of the building. The AO's assumption that the absence of legal proceedings by intending purchasers impacts tax levy is unfounded. The First Appellate Authority rightly treated the income as business income, given the assessee's sole business of renting buildings. Based on the AO's factual findings, the income cannot be treated as 'Income from House Property'. The High Court ruled in favor of the assessee, aligning with the precedents in Rayala Corporation and Chennai Properties cases.
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