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...
Page of 4828
Press 'Enter' after typing page number.
161 to 180 of 96556 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
HC determined that the transfer of a rice mill occurred upon execution of the sale agreement on 13.12.2016, not the registered sale deed on 21.3.2018. Relying on SC precedent in a similar case, the court held that the transaction enabling enjoyment of immovable property constitutes a transfer under section 2(47)(vi). The tribunal's initial conclusion was incorrect, as the entire sale consideration was paid at agreement execution, and the assessee was put in possession of the property. Consequently, the HC allowed the appeal, set aside the tribunal's order, and answered substantial legal questions in favor of the assessee.
HC determined that the transfer of a rice mill occurred upon execution of the sale agreement on 13.12.2016, not the registered sale deed on 21.3.2018. Relying on SC precedent in a similar case, the court held that the transaction enabling enjoyment of immovable property constitutes a transfer under section 2(47)(vi). The tribunal's initial conclusion was incorrect, as the entire sale consideration was paid at agreement execution, and the assessee was put in possession of the property. Consequently, the HC allowed the appeal, set aside the tribunal's order, and answered substantial legal questions in favor of the assessee.
Note: It is a system-generated summary and is for quick reference only.