Receipt of immovable property requires actual possession or enjoyment; redevelopment allotments exchanged for tenancy rights fall outside deemed incom...
Section 80P deduction covers Souharda credit societies, including qualifying surplus-deposit interest, subject to member KYC verification for cash dep...
Transfer-pricing benchmarking and capital-receipt principles sustained taxpayer relief, while unsupported property-advance write-offs remained disallo...
ITAT partially allowed the assessee's appeal across multiple tax-related issues. The Tribunal directed the AO to: (1) determine arm's length pricing for royalty payments using TNMM method, (2) recompute interest on outstanding receivables using LIBOR+200 points, (3) delete gratuity expenses disallowance under section 43B, (4) verify and grant foreign tax credit with proper documentation, (5) review Dividend Distribution Tax credit and related interest calculations, and (6) substantiate or remove ad-hoc interest levy. The decision emphasizes procedural fairness, statutory compliance, and principled tax assessment, allowing most grounds of appeal for statistical purposes with specific directional instructions to the Assessing Officer.
ITAT partially allowed the assessee's appeal across multiple tax-related issues. The Tribunal directed the AO to: (1) determine arm's length pricing for royalty payments using TNMM method, (2) recompute interest on outstanding receivables using LIBOR+200 points, (3) delete gratuity expenses disallowance under section 43B, (4) verify and grant foreign tax credit with proper documentation, (5) review Dividend Distribution Tax credit and related interest calculations, and (6) substantiate or remove ad-hoc interest levy. The decision emphasizes procedural fairness, statutory compliance, and principled tax assessment, allowing most grounds of appeal for statistical purposes with specific directional instructions to the Assessing Officer.
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