Employee stock-shortage penalties do not constitute consideration for services, preventing GST collection under Schedule II in employment relationship...
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...
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ITAT held that when computing capital gains for inherited/gifted property acquired pre-1981, the "first year asset held" refers to original ownership by previous owner, not date of gift transfer. Assessee correctly computed indexed cost of acquisition from April 2001 base date. Regarding property valuation, comparative sale instances must consider full ownership rights - 25% undivided share properties require upward adjustment. AO's determination of indexed acquisition cost was reasonable after examining documentation and explanations. The assessment order represented a plausible interpretation that was neither erroneous nor prejudicial to Revenue's interests. PCIT's revision under s.263 was unsustainable. Assessee's appeal allowed.
ITAT held that when computing capital gains for inherited/gifted property acquired pre-1981, the "first year asset held" refers to original ownership by previous owner, not date of gift transfer. Assessee correctly computed indexed cost of acquisition from April 2001 base date. Regarding property valuation, comparative sale instances must consider full ownership rights - 25% undivided share properties require upward adjustment. AO's determination of indexed acquisition cost was reasonable after examining documentation and explanations. The assessment order represented a plausible interpretation that was neither erroneous nor prejudicial to Revenue's interests. PCIT's revision under s.263 was unsustainable. Assessee's appeal allowed.
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