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 land and building acquired in 2007 constituted a capital asset, not stock-in-trade, observing the taxpayer's immediate construction for rental, prolonged efforts to lease (including negotiations and advertisements), consistent disclosure as a capital asset in income-tax and wealth-tax returns, and a six-year interregnum prior to sale. The tribunal characterized the disposal as a forced sale due to financial distress and protracted vacancy rather than a premeditated business venture. Consequently, the profit is taxable under the head "Capital Gains" and the assessee is entitled to exemption under s. 54EC. The orders of the AO and CIT(A) treating the receipts as business income were set aside; AO is directed to assess as returned.
ITAT held that the land and building acquired in 2007 constituted a capital asset, not stock-in-trade, observing the taxpayer's immediate construction for rental, prolonged efforts to lease (including negotiations and advertisements), consistent disclosure as a capital asset in income-tax and wealth-tax returns, and a six-year interregnum prior to sale. The tribunal characterized the disposal as a forced sale due to financial distress and protracted vacancy rather than a premeditated business venture. Consequently, the profit is taxable under the head "Capital Gains" and the assessee is entitled to exemption under s. 54EC. The orders of the AO and CIT(A) treating the receipts as business income were set aside; AO is directed to assess as returned.
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