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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Reopening of assessment u/s 147 for assessing Long Term Capital Gain on sale of land in Financial Year 2005-06. Assessing Officer (AO) adopted full value consideration u/s 50C(1) without issuing show cause notice or allowing cost of acquisition. Assessee claimed exemption u/s 54B. Appellate Tribunal held AO unjustified in making addition without allowing cost of acquisition or ascertaining fair market value as on 01.04.1981. Registered valuer reported guideline value lower than value adopted by AO, requiring verification. Fair market value to be determined u/s 50C(2). Matter remanded to AO for fresh adjudication considering cost of acquisition, fair market value u/s 50C(2), and exemption claim u/s 54B after giving assessee opportunity of hearing.
Reopening of assessment u/s 147 for assessing Long Term Capital Gain on sale of land in Financial Year 2005-06. Assessing Officer (AO) adopted full value consideration u/s 50C(1) without issuing show cause notice or allowing cost of acquisition. Assessee claimed exemption u/s 54B. Appellate Tribunal held AO unjustified in making addition without allowing cost of acquisition or ascertaining fair market value as on 01.04.1981. Registered valuer reported guideline value lower than value adopted by AO, requiring verification. Fair market value to be determined u/s 50C(2). Matter remanded to AO for fresh adjudication considering cost of acquisition, fair market value u/s 50C(2), and exemption claim u/s 54B after giving assessee opportunity of hearing.
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