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 dispute involving sections 50C, 56(2)(vii), and 69B regarding property valuation and tax assessment. The tribunal found that the Assessing Officer (AO) incorrectly applied section 69B instead of invoking exceptions under sections 50C and 56(2)(vii). The AO improperly relied on the Stamp Duty Valuation Authority's valuation without considering the actual consideration agreed in the purchase agreement. The tribunal held that the Assessee discharged its burden of proof and demonstrated the legitimacy of the property transaction. Regarding section 35AC, the tribunal remanded the matter to the AO for verification of donation-related documents and potential deduction allowance, directing a comprehensive review of submitted receipts and notifications.
ITAT adjudicated a dispute involving sections 50C, 56(2)(vii), and 69B regarding property valuation and tax assessment. The tribunal found that the Assessing Officer (AO) incorrectly applied section 69B instead of invoking exceptions under sections 50C and 56(2)(vii). The AO improperly relied on the Stamp Duty Valuation Authority's valuation without considering the actual consideration agreed in the purchase agreement. The tribunal held that the Assessee discharged its burden of proof and demonstrated the legitimacy of the property transaction. Regarding section 35AC, the tribunal remanded the matter to the AO for verification of donation-related documents and potential deduction allowance, directing a comprehensive review of submitted receipts and notifications.
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