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, insofar as Himachal Pradesh Tenancy and Land Reforms restrictions precluded transfer to a non-Himachali, the land remained exclusively with the assessee and amounts received from M/s Homeland Buildwell Pvt. Ltd. constituted an unsecured loan in the assessee's books; the Revenue had consistently recognized that position for earlier years. The Tribunal found that the unregistered collaboration was void and possession remained with the assessee; when the assessee discharged the outstanding loan by transferring 16.50 bighas pursuant to an arbitral decree, that transfer crystallised the sale and resultant capital gain for the year relevant to 2017-18. CIT(A)'s deletion of the AO's addition was upheld and the Revenue's appeal dismissed.
ITAT held that, insofar as Himachal Pradesh Tenancy and Land Reforms restrictions precluded transfer to a non-Himachali, the land remained exclusively with the assessee and amounts received from M/s Homeland Buildwell Pvt. Ltd. constituted an unsecured loan in the assessee's books; the Revenue had consistently recognized that position for earlier years. The Tribunal found that the unregistered collaboration was void and possession remained with the assessee; when the assessee discharged the outstanding loan by transferring 16.50 bighas pursuant to an arbitral decree, that transfer crystallised the sale and resultant capital gain for the year relevant to 2017-18. CIT(A)'s deletion of the AO's addition was upheld and the Revenue's appeal dismissed.
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