SEZ-unit profit deduction covers voluntary transfer-pricing adjustments, while exempt-income costs, foreign-exchange loss and ITeS comparables are exa...
Infrastructure-development deduction remains available to EPC contractors when substantive statutory conditions outweigh contractor labels in agreemen...
Explained Investment Sources: documented gifts and traceable salary savings supported deletion of additions for property and mutual-fund SIP investmen...
Internal comparable pricing supports arm's-length interest on compulsorily convertible debentures, preventing their recharacterisation as equity for t...
Taxpayer sold shops during AY 2017-18 and reported gains as Long Term Capital Gains (LTCG) in tax returns. While AO initially accepted this classification under section 143(3), the characterization was later disputed. ITAT ruled in favor of taxpayer, upholding LTCG treatment based on principle of consistency. Since revenue authorities had previously accepted property as investment and gains as LTCG, and there was no change in nature of property holding during assessment year, gains could not be reclassified as business income. Tribunal emphasized that consistent tax treatment must be maintained when underlying facts remain unchanged. Revenue's appeal dismissed.
Taxpayer sold shops during AY 2017-18 and reported gains as Long Term Capital Gains (LTCG) in tax returns. While AO initially accepted this classification under section 143(3), the characterization was later disputed. ITAT ruled in favor of taxpayer, upholding LTCG treatment based on principle of consistency. Since revenue authorities had previously accepted property as investment and gains as LTCG, and there was no change in nature of property holding during assessment year, gains could not be reclassified as business income. Tribunal emphasized that consistent tax treatment must be maintained when underlying facts remain unchanged. Revenue's appeal dismissed.
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