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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HC held that interest awarded in motor accident claim cases from the date of claim petition until award or appellate judgment is not taxable income. The compensatory interest, integral to calculating just compensation, does not constitute chargeable income under Income Tax Act. Sections 56(2)(viii), 145B(1), and 194A do not alter the non-taxable nature of such interest. The interest, being compensatory and linked to delayed computation of compensation, remains exempt from taxation. The ruling aligns with Supreme Court precedents interpreting the compensatory character of such interest awards in motor vehicle accident compensation cases.
HC held that interest awarded in motor accident claim cases from the date of claim petition until award or appellate judgment is not taxable income. The compensatory interest, integral to calculating just compensation, does not constitute chargeable income under Income Tax Act. Sections 56(2)(viii), 145B(1), and 194A do not alter the non-taxable nature of such interest. The interest, being compensatory and linked to delayed computation of compensation, remains exempt from taxation. The ruling aligns with Supreme Court precedents interpreting the compensatory character of such interest awards in motor vehicle accident compensation cases.
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