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 held that indexation benefit for property acquisition shall be calculated from the allotment date (3/12/2010), allowing cost indexation based on payments made during financial year 2010-11. The tribunal determined the property's acquisition date as the allotment letter date, permitting the assessee to claim indexed cost of acquisition. Additionally, the tribunal allowed brought forward long-term capital losses to be set off against long-term capital gains, noting no substantive reason existed to deny the claim, particularly since prior assessment orders had not challenged similar claims. Ground raised by the assessee was consequently allowed in entirety.
ITAT held that indexation benefit for property acquisition shall be calculated from the allotment date (3/12/2010), allowing cost indexation based on payments made during financial year 2010-11. The tribunal determined the property's acquisition date as the allotment letter date, permitting the assessee to claim indexed cost of acquisition. Additionally, the tribunal allowed brought forward long-term capital losses to be set off against long-term capital gains, noting no substantive reason existed to deny the claim, particularly since prior assessment orders had not challenged similar claims. Ground raised by the assessee was consequently allowed in entirety.
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