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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HC upheld ITAT's decision rejecting AO's addition u/s 68 and allowing exemption u/s 10(38) for LTCG. The assessee demonstrated legitimate share transactions not appearing in AIR reports for penny stocks. ITAT found AO erred by not considering substantial documentation proving genuine investments, including BSE trading resumption notice for Wagend Infra Venture Limited. The transactions were validated as non-speculative long-term investments, supported by precedent of department accepting similar LTCG claims from assessee's father. CIT(A)'s detailed analysis of documentary evidence was affirmed by ITAT. HC found no substantial question of law warranting interference.
HC upheld ITAT's decision rejecting AO's addition u/s 68 and allowing exemption u/s 10(38) for LTCG. The assessee demonstrated legitimate share transactions not appearing in AIR reports for penny stocks. ITAT found AO erred by not considering substantial documentation proving genuine investments, including BSE trading resumption notice for Wagend Infra Venture Limited. The transactions were validated as non-speculative long-term investments, supported by precedent of department accepting similar LTCG claims from assessee's father. CIT(A)'s detailed analysis of documentary evidence was affirmed by ITAT. HC found no substantial question of law warranting interference.
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