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 subject property was partly self-occupied and partly let out; assessing the entire annual letting value (ALV) as the assessee's income was erroneous. The Tribunal found the AO's adoption of an artificial rate (yielding a monthly rent based on 1,200 per sq.ft.) unsupported and derived from commercial listings, hence not a reliable or scientific basis for ALV. The matter was remitted to the AO to determine ALV solely for the let-out portion, applying legal principles and precedents for valuation and after affording the assessee adequate opportunity of being heard. The assessee's grounds were partly allowed for statistical purposes.
ITAT held that the subject property was partly self-occupied and partly let out; assessing the entire annual letting value (ALV) as the assessee's income was erroneous. The Tribunal found the AO's adoption of an artificial rate (yielding a monthly rent based on 1,200 per sq.ft.) unsupported and derived from commercial listings, hence not a reliable or scientific basis for ALV. The matter was remitted to the AO to determine ALV solely for the let-out portion, applying legal principles and precedents for valuation and after affording the assessee adequate opportunity of being heard. The assessee's grounds were partly allowed for statistical purposes.
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