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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HC determined that interest received for delayed compensation in compulsory land acquisition qualifies as part of the principal compensation amount. The interest shall be classified as "Capital Gains" under the I.T. Act and eligible for exemption under Section 10(37) if the acquired land is agricultural. The court held that such interest payments are not standalone interest as defined under Section 2(28A), and Section 56 provisions will not automatically apply. The determination depends on the specific factual context of each case. Ultimately, the decision was rendered in favor of the assessee, establishing that statutory interest in property acquisition scenarios should be treated as an integral component of the compensation itself.
HC determined that interest received for delayed compensation in compulsory land acquisition qualifies as part of the principal compensation amount. The interest shall be classified as "Capital Gains" under the I.T. Act and eligible for exemption under Section 10(37) if the acquired land is agricultural. The court held that such interest payments are not standalone interest as defined under Section 2(28A), and Section 56 provisions will not automatically apply. The determination depends on the specific factual context of each case. Ultimately, the decision was rendered in favor of the assessee, establishing that statutory interest in property acquisition scenarios should be treated as an integral component of the compensation itself.
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