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 resolved a capital gains taxation dispute involving an HUF's property transaction. The tribunal found that capital gains should have been computed in the seller/builder's hands, not the assessee-HUF's. Tax deductions by ultimate apartment buyers supported this conclusion. The tribunal determined that the Assessing Officer's addition of capital gains to the HUF's income was erroneous. Consequently, no capital gains would accrue to the assessee-HUF for the assessment year 2016-17, and the impugned addition was deleted. The assessee's appeal was allowed, effectively reversing the previous tax assessment and providing relief to the HUF.
ITAT resolved a capital gains taxation dispute involving an HUF's property transaction. The tribunal found that capital gains should have been computed in the seller/builder's hands, not the assessee-HUF's. Tax deductions by ultimate apartment buyers supported this conclusion. The tribunal determined that the Assessing Officer's addition of capital gains to the HUF's income was erroneous. Consequently, no capital gains would accrue to the assessee-HUF for the assessment year 2016-17, and the impugned addition was deleted. The assessee's appeal was allowed, effectively reversing the previous tax assessment and providing relief to the HUF.
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