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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The ITAT upheld the CIT(A)'s decision granting the assessee exemption under section 54B on long-term capital gains arising from the sale of residential land classified as agricultural land, evidenced by its use for crop cultivation for over two years prior to transfer. The tribunal accepted the English translation of the original regional language document as accurate. The assessee's reinvestment of the sale proceeds into agricultural land qualified for section 54B relief. Consequently, the appeal filed by the revenue was dismissed for lack of merit, confirming the assessee's entitlement to the exemption under section 54B in respect of capital gains under section 45.
The ITAT upheld the CIT(A)'s decision granting the assessee exemption under section 54B on long-term capital gains arising from the sale of residential land classified as agricultural land, evidenced by its use for crop cultivation for over two years prior to transfer. The tribunal accepted the English translation of the original regional language document as accurate. The assessee's reinvestment of the sale proceeds into agricultural land qualified for section 54B relief. Consequently, the appeal filed by the revenue was dismissed for lack of merit, confirming the assessee's entitlement to the exemption under section 54B in respect of capital gains under section 45.
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