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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The ITAT ruled against the revenue, quashing the reassessment proceedings initiated under section 147 after four years from the original assessment. The Tribunal determined that reopening was impermissible as the assessee had fully disclosed all material facts during the original assessment, and the reassessment was merely based on an audit objection constituting a change of opinion. On merits, ITAT rejected the revenue's contention that changing land use from cinema hall to commercial complex amounted to conversion of capital asset into stock-in-trade under section 45(2). The Tribunal clarified that entering into a development agreement does not automatically trigger section 45(2), particularly when the assessee consistently treated the property as a capital asset in its accounts and was not engaged in real estate business.
The ITAT ruled against the revenue, quashing the reassessment proceedings initiated under section 147 after four years from the original assessment. The Tribunal determined that reopening was impermissible as the assessee had fully disclosed all material facts during the original assessment, and the reassessment was merely based on an audit objection constituting a change of opinion. On merits, ITAT rejected the revenue's contention that changing land use from cinema hall to commercial complex amounted to conversion of capital asset into stock-in-trade under section 45(2). The Tribunal clarified that entering into a development agreement does not automatically trigger section 45(2), particularly when the assessee consistently treated the property as a capital asset in its accounts and was not engaged in real estate business.
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