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...
Page of 4828
Press 'Enter' after typing page number.
161 to 180 of 96556 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
The ITAT remitted the issue of valuation under section 56(2)(vii)(b) back to the AO for obtaining a revised detailed valuation report from the DVO, considering additional evidence submitted by the assessee challenging the comparability and encumbrance discounts applied by the original DVO report. The tribunal found merit in the assessee's contentions that the sale instances used by the DVO were not appropriate comparables due to differences in land size, type (leasehold vs. freehold), and nature of encumbrances. The tribunal declined to accept the purchase price as the correct value but held that the original DVO valuation was inadequately justified. Other grounds regarding applicability of section 56(2)(vii)(b) were left undecided. The appeal was allowed for statistical purposes.
The ITAT remitted the issue of valuation under section 56(2)(vii)(b) back to the AO for obtaining a revised detailed valuation report from the DVO, considering additional evidence submitted by the assessee challenging the comparability and encumbrance discounts applied by the original DVO report. The tribunal found merit in the assessee's contentions that the sale instances used by the DVO were not appropriate comparables due to differences in land size, type (leasehold vs. freehold), and nature of encumbrances. The tribunal declined to accept the purchase price as the correct value but held that the original DVO valuation was inadequately justified. Other grounds regarding applicability of section 56(2)(vii)(b) were left undecided. The appeal was allowed for statistical purposes.
Note: It is a system-generated summary and is for quick reference only.