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 determined that the period of holding for capital gains calculation should be reckoned from the date of the registered allotment agreement (03.10.2016), not the final payment date (21.08.2019). The Tribunal found that the taxpayer acquired title and interest in the property upon registration of the allotment agreement. The taxpayer correctly computed Long-Term Capital Gain by claiming indexation benefit only for payments made per the initial agreement, without indexing payments made in FY 2019-20. The AO's addition treating the gain as Short-Term Capital Gain was directed to be deleted, as the property qualified as a Long-Term Capital Asset based on the holding period from the allotment agreement date.
ITAT determined that the period of holding for capital gains calculation should be reckoned from the date of the registered allotment agreement (03.10.2016), not the final payment date (21.08.2019). The Tribunal found that the taxpayer acquired title and interest in the property upon registration of the allotment agreement. The taxpayer correctly computed Long-Term Capital Gain by claiming indexation benefit only for payments made per the initial agreement, without indexing payments made in FY 2019-20. The AO's addition treating the gain as Short-Term Capital Gain was directed to be deleted, as the property qualified as a Long-Term Capital Asset based on the holding period from the allotment agreement date.
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