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...
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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 adjudicated a capital gains tax exemption claim under Section 54, reversing lower authorities' decisions. The tribunal held that the assessee was entitled to exemption despite sale proceeds not being directly used for new property acquisition. The court emphasized that Section 54 does not mandate mandatory utilization of sale proceeds, but rather allows appropriation of capital gains towards new residential property investment. The tribunal found the assessee's investment in a new villa exceeded the sale consideration of the old residential house. Consequently, the tribunal set aside the previous order and directed the Assessing Officer to allow the exemption claim, ultimately deciding in favor of the assessee.
The ITAT adjudicated a capital gains tax exemption claim under Section 54, reversing lower authorities' decisions. The tribunal held that the assessee was entitled to exemption despite sale proceeds not being directly used for new property acquisition. The court emphasized that Section 54 does not mandate mandatory utilization of sale proceeds, but rather allows appropriation of capital gains towards new residential property investment. The tribunal found the assessee's investment in a new villa exceeded the sale consideration of the old residential house. Consequently, the tribunal set aside the previous order and directed the Assessing Officer to allow the exemption claim, ultimately deciding in favor of the assessee.
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