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 remanded the case back to the Assessing Officer (AO) to establish critical factual elements regarding a property transaction involving ten flats. The tribunal directed the AO to comprehensively investigate and document: (1) sale consideration in profit and loss account, (2) cost of flats sold, (3) net profit declaration during survey, (4) liquidation status of the purchasing entity, and (5) possession status of the flats. The grounds raised by the assessee were allowed for statistical purposes, with the primary objective of determining whether the transaction constitutes a benefit under Section 28(iv) of the Income Tax Act. The case requires further detailed examination to conclusively determine the tax treatment of the transaction.
ITAT remanded the case back to the Assessing Officer (AO) to establish critical factual elements regarding a property transaction involving ten flats. The tribunal directed the AO to comprehensively investigate and document: (1) sale consideration in profit and loss account, (2) cost of flats sold, (3) net profit declaration during survey, (4) liquidation status of the purchasing entity, and (5) possession status of the flats. The grounds raised by the assessee were allowed for statistical purposes, with the primary objective of determining whether the transaction constitutes a benefit under Section 28(iv) of the Income Tax Act. The case requires further detailed examination to conclusively determine the tax treatment of the transaction.
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