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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
ITAT held that the transfer of the plot occurred in the previous year relevant to AY 2010-11 (FY 2009-10), since offer, acceptance and consideration were completed in FY 2009-10, payment was made and possession delivered, and the transaction's genuineness was subsequently recorded in a deed. The Tribunal found no contention of unfulfilled conditions and noted the assessee had declared the capital gains in AY 2010-11. Consequently, the disputed capital gains could not be taxed in the later assessment year under consideration. Grounds No. 1 and 2 raised by the assessee were allowed.
ITAT held that the transfer of the plot occurred in the previous year relevant to AY 2010-11 (FY 2009-10), since offer, acceptance and consideration were completed in FY 2009-10, payment was made and possession delivered, and the transaction's genuineness was subsequently recorded in a deed. The Tribunal found no contention of unfulfilled conditions and noted the assessee had declared the capital gains in AY 2010-11. Consequently, the disputed capital gains could not be taxed in the later assessment year under consideration. Grounds No. 1 and 2 raised by the assessee were allowed.
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