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 allowed the assessee's appeal, holding that the assessee was entitled to exemption under section 54F for long-term capital gains. The Tribunal found that the entire sale consideration had been bona fide invested in acquisition of a plot for construction, and delay in commencement/completion beyond the three-year period was attributable to factors beyond the assessee's control (not the assessee's default). Given that the assessee ultimately relinquished rights in the original plot and reinvested the recovered proceeds in a residential property, and that section 54F is a beneficial provision, the assessee could not be disentitled from the exemption; relief granted.
The ITAT allowed the assessee's appeal, holding that the assessee was entitled to exemption under section 54F for long-term capital gains. The Tribunal found that the entire sale consideration had been bona fide invested in acquisition of a plot for construction, and delay in commencement/completion beyond the three-year period was attributable to factors beyond the assessee's control (not the assessee's default). Given that the assessee ultimately relinquished rights in the original plot and reinvested the recovered proceeds in a residential property, and that section 54F is a beneficial provision, the assessee could not be disentitled from the exemption; relief granted.
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