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 dismissed appellant's challenge to taxation of compensation received for compulsory land acquisition under NHAI Act, 1956. The tribunal held that compensation received on land acquisition under NHAI Act constitutes taxable short-term capital gain, rejecting exemption claims under Section 10 of Income Tax Act, 1961. Following precedent in Heritage Buildcon case and CBDT Circular 36/2016, ITAT determined that since NHAI Act falls under Fourth Schedule of RFCTLARR Act, 2013, no income tax exemption applies per Sections 96 and 105(1) of RFCTLARR Act read with CBDT's office memorandum dated 06.06.2019. The tribunal upheld CIT(Appeals) order confirming the addition and dismissed the appellant's ground of appeal, establishing that compulsory acquisition compensation under specified enactments remains subject to capital gains taxation.
ITAT dismissed appellant's challenge to taxation of compensation received for compulsory land acquisition under NHAI Act, 1956. The tribunal held that compensation received on land acquisition under NHAI Act constitutes taxable short-term capital gain, rejecting exemption claims under Section 10 of Income Tax Act, 1961. Following precedent in Heritage Buildcon case and CBDT Circular 36/2016, ITAT determined that since NHAI Act falls under Fourth Schedule of RFCTLARR Act, 2013, no income tax exemption applies per Sections 96 and 105(1) of RFCTLARR Act read with CBDT's office memorandum dated 06.06.2019. The tribunal upheld CIT(Appeals) order confirming the addition and dismissed the appellant's ground of appeal, establishing that compulsory acquisition compensation under specified enactments remains subject to capital gains taxation.
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