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 Appellate Tribunal (ITAT) upheld the appellate order granting relief under Section 54F to the assessee trust. The ITAT found the trust to be a private trust for identified beneficiaries (not a charitable AOP), such that trust income is attributable to beneficiaries; the transaction-purchase of land, sale of flat and reinvestment of capital gains into a residential house-would, absent the trust, have been effected in beneficiaries' names and qualified for exemption under Section 54. Consequently, the CIT(A)'s allowance of Section 54F relief was affirmed and the revenue's challenge dismissed.
The Appellate Tribunal (ITAT) upheld the appellate order granting relief under Section 54F to the assessee trust. The ITAT found the trust to be a private trust for identified beneficiaries (not a charitable AOP), such that trust income is attributable to beneficiaries; the transaction-purchase of land, sale of flat and reinvestment of capital gains into a residential house-would, absent the trust, have been effected in beneficiaries' names and qualified for exemption under Section 54. Consequently, the CIT(A)'s allowance of Section 54F relief was affirmed and the revenue's challenge dismissed.
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