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 allowed the assessee's claim for deduction u/s 54F despite the Assessing Officer's objections. It held that the assessee had invested the entire net consideration in constructing a residential house within the stipulated period, satisfying the requirements of Section 54F. The mere fact that the assessee was associated with the concern developing the housing project could not be grounds for denying the deduction. The ITAT relied on judicial precedents, including the Karnataka High Court's decision in CIT vs. Smt. B.S. Shantakumari and the Supreme Court's ruling in Fibre Boards (P) Ltd., to conclude that the assessee was entitled to the deduction u/s 54F.
The ITAT allowed the assessee's claim for deduction u/s 54F despite the Assessing Officer's objections. It held that the assessee had invested the entire net consideration in constructing a residential house within the stipulated period, satisfying the requirements of Section 54F. The mere fact that the assessee was associated with the concern developing the housing project could not be grounds for denying the deduction. The ITAT relied on judicial precedents, including the Karnataka High Court's decision in CIT vs. Smt. B.S. Shantakumari and the Supreme Court's ruling in Fibre Boards (P) Ltd., to conclude that the assessee was entitled to the deduction u/s 54F.
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