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 affirms the order of the Ld. CIT(A) allowing the assessee's claim of exemption under ss. 54F/54EC and holding the entire proceeds as long-term capital gains; the revenue's grounds are dismissed. The Tribunal found no infirmity in CIT(A)'s conclusion that denying exemption would occasion double taxation, noting documentary evidence and prior assessment treatment where no portion was taxed in another person's hands. On the issue of treating 50% as income from other sources, ITAT accepted the assessee's sole-beneficiary status and the evidentiary record substantiating receipt of the entire sale consideration, thereby upholding CIT(A)'s treatment of the full amount as LTCG.
ITAT affirms the order of the Ld. CIT(A) allowing the assessee's claim of exemption under ss. 54F/54EC and holding the entire proceeds as long-term capital gains; the revenue's grounds are dismissed. The Tribunal found no infirmity in CIT(A)'s conclusion that denying exemption would occasion double taxation, noting documentary evidence and prior assessment treatment where no portion was taxed in another person's hands. On the issue of treating 50% as income from other sources, ITAT accepted the assessee's sole-beneficiary status and the evidentiary record substantiating receipt of the entire sale consideration, thereby upholding CIT(A)'s treatment of the full amount as LTCG.
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