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 regarding the tax treatment of property rights relinquishment. The tribunal determined that the compensation received for surrendering possessory and beneficial interest constitutes long-term capital gains under Section 2(14) and 2(47), not income from other sources. The tribunal validated the assessee's claim, recognizing her prolonged possession and settled rights. Consequently, the tribunal allowed the assessee's appeal, affirming the long-term capital gains assessment and permitting deductions under Sections 54 and 54EC. The voluntary declaration of consideration as long-term capital gains in the income return was upheld, and the reassessment by the Assessing Officer was deemed unsustainable.
ITAT adjudicated a dispute regarding the tax treatment of property rights relinquishment. The tribunal determined that the compensation received for surrendering possessory and beneficial interest constitutes long-term capital gains under Section 2(14) and 2(47), not income from other sources. The tribunal validated the assessee's claim, recognizing her prolonged possession and settled rights. Consequently, the tribunal allowed the assessee's appeal, affirming the long-term capital gains assessment and permitting deductions under Sections 54 and 54EC. The voluntary declaration of consideration as long-term capital gains in the income return was upheld, and the reassessment by the Assessing Officer was deemed unsustainable.
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