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...
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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 held that the subject lands qualify as agricultural lands under section 2(14)(iii)(b), exempting them from long-term capital gains taxation. The tribunal considered evidence including Patta certificates, Chitta Adangal, and revenue records demonstrating agricultural classification. Referencing prior Madras HC precedents, the tribunal affirmed land's agricultural status based on official documentation, irrespective of actual cultivation. Consequently, the tribunal set aside the CIT(A)'s order confirming capital gains addition and allowed the assessee's appeal. Additionally, regarding section 14A disallowance, the tribunal directed the Assessing Officer to restrict disallowance proportionate to the exempt income earned during the relevant previous year.
ITAT held that the subject lands qualify as agricultural lands under section 2(14)(iii)(b), exempting them from long-term capital gains taxation. The tribunal considered evidence including Patta certificates, Chitta Adangal, and revenue records demonstrating agricultural classification. Referencing prior Madras HC precedents, the tribunal affirmed land's agricultural status based on official documentation, irrespective of actual cultivation. Consequently, the tribunal set aside the CIT(A)'s order confirming capital gains addition and allowed the assessee's appeal. Additionally, regarding section 14A disallowance, the tribunal directed the Assessing Officer to restrict disallowance proportionate to the exempt income earned during the relevant previous year.
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