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 matter to AO for verification of agricultural land's distance from GHMC municipal limits as of sale date 07.09.2007. Land constitutes capital asset under Section 2(14)(iii)(b) if within 8 km radius of notified municipality. Tribunal upheld CIT(A)'s allowance of Section 54F exemption but clarified investment deadline extends to delayed return filing date under Section 139(4), not merely due date. Section 54B exemption properly restricted to registered sale deed values, rejecting higher agreement amounts. Cost of improvement deduction denied due to insufficient substantiation beyond rough notebook entries. AO directed to allow investments made up to delayed return filing date and verify land distance for capital asset determination.
ITAT remanded matter to AO for verification of agricultural land's distance from GHMC municipal limits as of sale date 07.09.2007. Land constitutes capital asset under Section 2(14)(iii)(b) if within 8 km radius of notified municipality. Tribunal upheld CIT(A)'s allowance of Section 54F exemption but clarified investment deadline extends to delayed return filing date under Section 139(4), not merely due date. Section 54B exemption properly restricted to registered sale deed values, rejecting higher agreement amounts. Cost of improvement deduction denied due to insufficient substantiation beyond rough notebook entries. AO directed to allow investments made up to delayed return filing date and verify land distance for capital asset determination.
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