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 adjudicated a tax dispute involving wind power generation unit transfer. The tribunal held that the transfer between parties constituted a valid slump sale, thereby enabling deduction under Section 80IA(4). The assessee's claim for deduction was substantiated by proper documentation, including Form 3CEA and transaction certificates. The tribunal distinguished the case from a prior precedent involving windmill sales, affirming the eligibility for tax deduction. Furthermore, the tribunal rejected the disallowance of depreciation, confirming that depreciation was correctly computed based on the asset's written down value and in compliance with Section 43(1) of the Income Tax Act. The appeal was allowed in favor of the assessee.
ITAT adjudicated a tax dispute involving wind power generation unit transfer. The tribunal held that the transfer between parties constituted a valid slump sale, thereby enabling deduction under Section 80IA(4). The assessee's claim for deduction was substantiated by proper documentation, including Form 3CEA and transaction certificates. The tribunal distinguished the case from a prior precedent involving windmill sales, affirming the eligibility for tax deduction. Furthermore, the tribunal rejected the disallowance of depreciation, confirming that depreciation was correctly computed based on the asset's written down value and in compliance with Section 43(1) of the Income Tax Act. The appeal was allowed in favor of the assessee.
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