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 set aside the assessment to the file of the AO and directed recomputation of long-term capital gains (LTCG). The AO must enquire into and allow deduction for cost of acquisition and cost of improvement, if any, after calling for and verifying requisite particulars, because denial without such inquiry was impermissible and the Department must not derive advantage from an assessee's ignorance. The tribunal also directed allowance of deduction under s.54F for construction expenses incurred up to the extended due date under s.139(4), subject to verification that the assessee did not own more than one residential property on the date of sale. The assessee's ground is allowed for statistical purposes.
ITAT set aside the assessment to the file of the AO and directed recomputation of long-term capital gains (LTCG). The AO must enquire into and allow deduction for cost of acquisition and cost of improvement, if any, after calling for and verifying requisite particulars, because denial without such inquiry was impermissible and the Department must not derive advantage from an assessee's ignorance. The tribunal also directed allowance of deduction under s.54F for construction expenses incurred up to the extended due date under s.139(4), subject to verification that the assessee did not own more than one residential property on the date of sale. The assessee's ground is allowed for statistical purposes.
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