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 ITAT upheld the CIT(A)'s order allowing the assessee's claim for exemption u/s 10(34A) and taxation of Long Term Capital Gains (LTCG) at the special rate u/s 112. The ITAT rejected the AO's disallowance of exemption claimed u/s 10(34A) and treatment of LTCG as income from other sources, denying the benefit of Section 112. The ITAT found no infirmity in the CIT(A)'s well-reasoned order based on facts and law, concluding that the assessee met the conditions for Section 10(34A) exemption and was entitled to the concessional tax rate on LTCG u/s 112. The Revenue's appeal was dismissed on both counts.
The ITAT upheld the CIT(A)'s order allowing the assessee's claim for exemption u/s 10(34A) and taxation of Long Term Capital Gains (LTCG) at the special rate u/s 112. The ITAT rejected the AO's disallowance of exemption claimed u/s 10(34A) and treatment of LTCG as income from other sources, denying the benefit of Section 112. The ITAT found no infirmity in the CIT(A)'s well-reasoned order based on facts and law, concluding that the assessee met the conditions for Section 10(34A) exemption and was entitled to the concessional tax rate on LTCG u/s 112. The Revenue's appeal was dismissed on both counts.
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