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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In a case concerning LTCG on sale of inherited agricultural land, the ITAT determined that the appropriate cost of acquisition as on 01.04.1981 should be Rs. 150 per sq. yard, calculated by applying a 57% increase to the 1962 value of Rs. 85. The AO was directed to recalculate the indexed cost accordingly. Regarding deduction u/s 54F, the Tribunal allowed the assessee's claim for property purchased in his widowed mother's name, noting the peculiar inheritance circumstances. The Tribunal recognized that under Hindu Succession Act principles, apportioning the sale consideration would result in tax neutrality since the mother's portion was invested in property qualifying for deduction u/s 54F. The assessee's appeal was partly allowed.
In a case concerning LTCG on sale of inherited agricultural land, the ITAT determined that the appropriate cost of acquisition as on 01.04.1981 should be Rs. 150 per sq. yard, calculated by applying a 57% increase to the 1962 value of Rs. 85. The AO was directed to recalculate the indexed cost accordingly. Regarding deduction u/s 54F, the Tribunal allowed the assessee's claim for property purchased in his widowed mother's name, noting the peculiar inheritance circumstances. The Tribunal recognized that under Hindu Succession Act principles, apportioning the sale consideration would result in tax neutrality since the mother's portion was invested in property qualifying for deduction u/s 54F. The assessee's appeal was partly allowed.
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