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 allowed the appellant's appeal for statistical purposes, holding that indexation benefit must be computed from the year of construction (FY 2002-03) as recited in the sale deed, reversing the CIT(A)'s direction to commence indexation from 2011. The Tribunal directed the AO to treat cost of acquisition as including construction cost for both ground and first floors (2255.5 sq. ft. each) at Rs. 261 per sq. ft. The AO is further directed to verify submitted sale deed documents relating to the property sold for Rs. 9,28,000 and, upon proof, to allow the claimed cost of acquisition while computing capital gains.
ITAT allowed the appellant's appeal for statistical purposes, holding that indexation benefit must be computed from the year of construction (FY 2002-03) as recited in the sale deed, reversing the CIT(A)'s direction to commence indexation from 2011. The Tribunal directed the AO to treat cost of acquisition as including construction cost for both ground and first floors (2255.5 sq. ft. each) at Rs. 261 per sq. ft. The AO is further directed to verify submitted sale deed documents relating to the property sold for Rs. 9,28,000 and, upon proof, to allow the claimed cost of acquisition while computing capital gains.
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