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 quashed reassessment u/s 147 finding AO failed to apply mind with undated reasons based on incorrect facts and uncorroborated information without independent verification. Tribunal held gift of equity shares completed on 09.04.2009 per gift deed dated 30.04.2009, applying doctrine of relating back principle. Since Section 56(2)(vii)(c) became effective from 01.10.2009 for AY 2010-11, provisions were inapplicable to gifts executed prior to effective date. AO erroneously treated entire Rs.100 per share including Rs.90 premium as taxable income contravening statutory provisions. Subsequent stamping on 18.09.2010 at company's request did not alter original gift completion date. No additions warranted for AY 2011-12. Appeal allowed.
ITAT quashed reassessment u/s 147 finding AO failed to apply mind with undated reasons based on incorrect facts and uncorroborated information without independent verification. Tribunal held gift of equity shares completed on 09.04.2009 per gift deed dated 30.04.2009, applying doctrine of relating back principle. Since Section 56(2)(vii)(c) became effective from 01.10.2009 for AY 2010-11, provisions were inapplicable to gifts executed prior to effective date. AO erroneously treated entire Rs.100 per share including Rs.90 premium as taxable income contravening statutory provisions. Subsequent stamping on 18.09.2010 at company's request did not alter original gift completion date. No additions warranted for AY 2011-12. Appeal allowed.
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