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...
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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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The HC dismissed the Revenue's appeal regarding application of Section 50C for capital gains computation. The assessee had entered into a registered agreement to sell prior to 16.09.2004 with a payment schedule, followed by execution of the sale deed on 16.09.2004 when circle rates were revised upwards. The Revenue contended that the revised circle rate on the sale deed date should apply under Section 50C. The HC held that since the transaction value was commensurate with the circle rate at the material time of the original agreement, subsequent circle rate increases would not affect Section 50C application. The decision followed the precedent in Modipon Limited, confirming that the proviso to Section 50C does not apply retrospectively when the original transaction value matched prevailing circle rates.
The HC dismissed the Revenue's appeal regarding application of Section 50C for capital gains computation. The assessee had entered into a registered agreement to sell prior to 16.09.2004 with a payment schedule, followed by execution of the sale deed on 16.09.2004 when circle rates were revised upwards. The Revenue contended that the revised circle rate on the sale deed date should apply under Section 50C. The HC held that since the transaction value was commensurate with the circle rate at the material time of the original agreement, subsequent circle rate increases would not affect Section 50C application. The decision followed the precedent in Modipon Limited, confirming that the proviso to Section 50C does not apply retrospectively when the original transaction value matched prevailing circle rates.
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