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 addressed the taxability year and valuation of income arising from land exchange under Joint Development Agreement where assessee converted capital asset to stock-in-trade. The assessee received Occupancy Certificate on 21.7.2016 for completed commercial complex. ITAT's coordinate bench previously determined taxability occurs upon actual sale of building, not in assessment year 2017-18. Regarding valuation dispute at Rs. 3085.50 per sq ft, ITAT held CIT(A) lacked valuation expertise. Matter remanded to AO with directions to refer valuation to departmental valuation officer and examine the actual year of sale when assessee offered income for taxation, ensuring proper determination of taxability year and accurate valuation assessment.
ITAT addressed the taxability year and valuation of income arising from land exchange under Joint Development Agreement where assessee converted capital asset to stock-in-trade. The assessee received Occupancy Certificate on 21.7.2016 for completed commercial complex. ITAT's coordinate bench previously determined taxability occurs upon actual sale of building, not in assessment year 2017-18. Regarding valuation dispute at Rs. 3085.50 per sq ft, ITAT held CIT(A) lacked valuation expertise. Matter remanded to AO with directions to refer valuation to departmental valuation officer and examine the actual year of sale when assessee offered income for taxation, ensuring proper determination of taxability year and accurate valuation assessment.
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