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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ITAT upheld revision under s.263 regarding taxation of accumulated interest on debentures converted to equity shares. Assessee's contention of following cash system and deferring interest taxation to share sale was rejected. Upon conversion, entire interest amount of Rs.61.97 Lacs deemed received when debentures converted to shares at face value plus accumulated interest. While conversion itself not transfer per s.47(x), accrued interest component taxable in conversion year. Cost of acquisition for future capital gains would include both face value and interest per s.49(2A). Assessee's double taxation argument rejected as fundamentally flawed. AO's acceptance of return deemed erroneous and prejudicial to revenue interests, making revision order valid.
ITAT upheld revision under s.263 regarding taxation of accumulated interest on debentures converted to equity shares. Assessee's contention of following cash system and deferring interest taxation to share sale was rejected. Upon conversion, entire interest amount of Rs.61.97 Lacs deemed received when debentures converted to shares at face value plus accumulated interest. While conversion itself not transfer per s.47(x), accrued interest component taxable in conversion year. Cost of acquisition for future capital gains would include both face value and interest per s.49(2A). Assessee's double taxation argument rejected as fundamentally flawed. AO's acceptance of return deemed erroneous and prejudicial to revenue interests, making revision order valid.
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