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 HC partially allowed the appeal, ruling on two key issues. First, it confirmed that lands in Egathur and Navalur Villages qualified as agricultural lands under s.2(14) of the Act, being situated beyond 8km from municipal limits, thus exempt from being considered capital assets. The HC held that "Municipality" encompasses all local bodies regardless of specific nomenclature. Second, regarding NABARD bonds investment for s.54EC deduction, the HC reversed the Tribunal's finding, determining that the assessee could claim exemption only to the extent of Rs. 8,55,54,167/- out of Rs. 10 Crores, as funds from a property sold on 13.02.2006 were not available for investment made on 26.11.2005.
The HC partially allowed the appeal, ruling on two key issues. First, it confirmed that lands in Egathur and Navalur Villages qualified as agricultural lands under s.2(14) of the Act, being situated beyond 8km from municipal limits, thus exempt from being considered capital assets. The HC held that "Municipality" encompasses all local bodies regardless of specific nomenclature. Second, regarding NABARD bonds investment for s.54EC deduction, the HC reversed the Tribunal's finding, determining that the assessee could claim exemption only to the extent of Rs. 8,55,54,167/- out of Rs. 10 Crores, as funds from a property sold on 13.02.2006 were not available for investment made on 26.11.2005.
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