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 held that the assessee failed to utilize amounts held in a Capital Gains Account Scheme (CGAS) to construct a residential property within the statutory period and therefore properly offered Rs. 6.45 crores as long-term capital gains in the assessment year 2020-21, discharging the tax liability. The Tribunal found that the assessee had complied with section 54 by depositing the entire long-term capital gains in CGAS before filing the return for AY 2017-18, and that the Revenue and the ld. CIT(A) erred in taxing that sum in AY 2017-18. The Tribunal set aside the CIT(A) order and directed the AO to delete the addition and recompute total income; appeal allowed.
ITAT held that the assessee failed to utilize amounts held in a Capital Gains Account Scheme (CGAS) to construct a residential property within the statutory period and therefore properly offered Rs. 6.45 crores as long-term capital gains in the assessment year 2020-21, discharging the tax liability. The Tribunal found that the assessee had complied with section 54 by depositing the entire long-term capital gains in CGAS before filing the return for AY 2017-18, and that the Revenue and the ld. CIT(A) erred in taxing that sum in AY 2017-18. The Tribunal set aside the CIT(A) order and directed the AO to delete the addition and recompute total income; appeal allowed.
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