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 ruled that provisions of section 115BBE(2), which deny set-off of losses against income under section 69, apply prospectively from 01/04/2017 and are not applicable to assessment year 2014-15. The tribunal relied on Vijaya Hospitality and Resorts Ltd. precedent from Kerala HC, which established that amendments to section 115BBE(2) introduced by Finance Act, 2016 take effect from AY 2017-18 onwards. Accordingly, ITAT directed the AO to permit the appellant to set off house property losses against income assessed under section 69, allowing the appellant's grounds of appeal.
ITAT ruled that provisions of section 115BBE(2), which deny set-off of losses against income under section 69, apply prospectively from 01/04/2017 and are not applicable to assessment year 2014-15. The tribunal relied on Vijaya Hospitality and Resorts Ltd. precedent from Kerala HC, which established that amendments to section 115BBE(2) introduced by Finance Act, 2016 take effect from AY 2017-18 onwards. Accordingly, ITAT directed the AO to permit the appellant to set off house property losses against income assessed under section 69, allowing the appellant's grounds of appeal.
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