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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The ITAT addressed the determination of Annual Letting Value (ALV) under Section 23(1)(a) for unsold property units held as stock-in-trade. Relying on precedents from Bombay and Delhi High Courts, the tribunal mandated that notional rent calculation must align with municipal laws, considering potential rent inflation or deflation, without exceeding standard rent under applicable Rent Control Legislation. The tribunal directed the Assessing Officer to determine notional rent using established valuation methods, specifically referencing decisions in Tip Top Typography and Inorbit Malls. The ruling emphasizes a nuanced approach to calculating hypothetical rental income, ensuring compliance with municipal valuation principles and statutory guidelines.
The ITAT addressed the determination of Annual Letting Value (ALV) under Section 23(1)(a) for unsold property units held as stock-in-trade. Relying on precedents from Bombay and Delhi High Courts, the tribunal mandated that notional rent calculation must align with municipal laws, considering potential rent inflation or deflation, without exceeding standard rent under applicable Rent Control Legislation. The tribunal directed the Assessing Officer to determine notional rent using established valuation methods, specifically referencing decisions in Tip Top Typography and Inorbit Malls. The ruling emphasizes a nuanced approach to calculating hypothetical rental income, ensuring compliance with municipal valuation principles and statutory guidelines.
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