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 held that the addition of capital gains income in AY 2015-16 was unsustainable as the original transfer of land by the assessee and family members to TTCIPL occurred on 19.04.2010 and was already assessed for AY 2011-12. The subsequent sale deed dated 16.03.2015, involving the same land and survey number, represented a sale by the original buyer, not a fresh transfer by the assessee. The assessee's name appearing in the later deed only confirmed the chain of title and did not trigger new capital gains liability. The Tribunal noted inconsistent treatment by the Revenue in similar cases and found no basis for reassessment under Section 147 for the later year. Consequently, the capital gains addition for AY 2015-16 was deleted and the assessee's appeal allowed.
The ITAT held that the addition of capital gains income in AY 2015-16 was unsustainable as the original transfer of land by the assessee and family members to TTCIPL occurred on 19.04.2010 and was already assessed for AY 2011-12. The subsequent sale deed dated 16.03.2015, involving the same land and survey number, represented a sale by the original buyer, not a fresh transfer by the assessee. The assessee's name appearing in the later deed only confirmed the chain of title and did not trigger new capital gains liability. The Tribunal noted inconsistent treatment by the Revenue in similar cases and found no basis for reassessment under Section 147 for the later year. Consequently, the capital gains addition for AY 2015-16 was deleted and the assessee's appeal allowed.
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