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 upheld the denial of deduction under section 54F for LTCG. While the assessee had purchased the plot and obtained construction approvals before selling the original asset, the tribunal found this insufficient to qualify for the deduction. Per section 54F requirements, the assessee needed to either purchase a house within the period from 19.01.2006 to 18.01.2009 or construct one between 19.01.2007 and 18.01.2010. The valuation report indicated construction completion between 2005-06 and 2007-08, establishing that the assessee neither purchased a house within one year nor constructed one within the prescribed statutory period. The order denying the section 54F deduction was consequently confirmed.
The ITAT upheld the denial of deduction under section 54F for LTCG. While the assessee had purchased the plot and obtained construction approvals before selling the original asset, the tribunal found this insufficient to qualify for the deduction. Per section 54F requirements, the assessee needed to either purchase a house within the period from 19.01.2006 to 18.01.2009 or construct one between 19.01.2007 and 18.01.2010. The valuation report indicated construction completion between 2005-06 and 2007-08, establishing that the assessee neither purchased a house within one year nor constructed one within the prescribed statutory period. The order denying the section 54F deduction was consequently confirmed.
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