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 no "transfer" under section 2(47)(v) occurred in the assessment year 2010-11 because the JDA neither conferred ownership nor delivered possession or control of the land (no part performance under section 53A), and refundable interest-free deposits negated any absolute transfer; consequently the AO's deemed capital-gain assessment and resulting addition (confirmed by the CIT(A)) were deleted and the assessee's appeal allowed. The Tribunal further held receipts from sale of flats under the JDA constitute capital gains, not business income, and directed allowance of indexed cost of improvements and selling expenses; sale proceeds from plots were likewise held taxable as capital gains.
The ITAT held that no "transfer" under section 2(47)(v) occurred in the assessment year 2010-11 because the JDA neither conferred ownership nor delivered possession or control of the land (no part performance under section 53A), and refundable interest-free deposits negated any absolute transfer; consequently the AO's deemed capital-gain assessment and resulting addition (confirmed by the CIT(A)) were deleted and the assessee's appeal allowed. The Tribunal further held receipts from sale of flats under the JDA constitute capital gains, not business income, and directed allowance of indexed cost of improvements and selling expenses; sale proceeds from plots were likewise held taxable as capital gains.
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