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 held that gains from sale of trademarks "Coldarin" and "Raricap" acquired prior to 01/04/1998 qualify as Long Term Capital Gains, not Short Term Capital Gains. Section 50 was inapplicable as intangible assets were not part of depreciable block assets before Finance Act 1998 amendment. Since the trademarks were acquired in FY 1992-93 and 1997-98 when no statutory provision mandated inclusion of intangibles in block assets, depreciation provisions under Section 50 cannot apply. ITAT overturned lower authorities' treatment of gains as STCG, ruling in appellant's favor to classify proceeds as LTCG for tax purposes.
ITAT held that gains from sale of trademarks "Coldarin" and "Raricap" acquired prior to 01/04/1998 qualify as Long Term Capital Gains, not Short Term Capital Gains. Section 50 was inapplicable as intangible assets were not part of depreciable block assets before Finance Act 1998 amendment. Since the trademarks were acquired in FY 1992-93 and 1997-98 when no statutory provision mandated inclusion of intangibles in block assets, depreciation provisions under Section 50 cannot apply. ITAT overturned lower authorities' treatment of gains as STCG, ruling in appellant's favor to classify proceeds as LTCG for tax purposes.
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