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 allowed the appeal and directed the AO to delete the Rs.27,00,000 addition made to the assessee's income. The Tribunal found the assessee's spouse had disclosed the entire sale consideration in his return, and taxing the same receipt in the assessee's hands would amount to double taxation. Further, the impugned flat was acquired in October 2007 and sold in July 2019, qualifying for long-term capital gains treatment; indexed cost computation yields a capital loss, rendering the AO's short-term capital gains assessment unsustainable. The AO was held to have failed to verify available records, and the addition was quashed.
ITAT allowed the appeal and directed the AO to delete the Rs.27,00,000 addition made to the assessee's income. The Tribunal found the assessee's spouse had disclosed the entire sale consideration in his return, and taxing the same receipt in the assessee's hands would amount to double taxation. Further, the impugned flat was acquired in October 2007 and sold in July 2019, qualifying for long-term capital gains treatment; indexed cost computation yields a capital loss, rendering the AO's short-term capital gains assessment unsustainable. The AO was held to have failed to verify available records, and the addition was quashed.
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