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 the term "purchase" in s. 54F(2) bears a wider connotation and is not confined to execution of a registered sale deed or actual possession; a liberal construction is warranted to effectuate the fiscal object of allowing rollover relief on reinvestment in residential property. The assessee's claim for exemption under s. 54F was upheld. Because the assessee's investment in the new residential house within the prescribed period was less than the net sale consideration of the original capital assets, the AO was directed to compute exemption pro rata: allow exemption in the proportion that the cost of the new house (investment made within the stipulated period) bears to the net sale consideration.
ITAT held that the term "purchase" in s. 54F(2) bears a wider connotation and is not confined to execution of a registered sale deed or actual possession; a liberal construction is warranted to effectuate the fiscal object of allowing rollover relief on reinvestment in residential property. The assessee's claim for exemption under s. 54F was upheld. Because the assessee's investment in the new residential house within the prescribed period was less than the net sale consideration of the original capital assets, the AO was directed to compute exemption pro rata: allow exemption in the proportion that the cost of the new house (investment made within the stipulated period) bears to the net sale consideration.
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