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...
The ITAT set aside the CIT(A)'s order and remanded the matter to the jurisdictional AO for fresh adjudication under section 56(2)(x), directing the AO to consider stamp duty, additional stamp duty, registration charges, legal fees and other taxes/charges as part of the cost of acquisition when estimating fair market value. The AO must afford the assessee a proper opportunity of hearing and permit submission of supporting documentation. The assessee is directed to furnish all necessary details to the JA(O) for reconsideration. The appeal is allowed for statistical purposes and the original addition is vacated pending fresh determination by the AO.
The ITAT set aside the CIT(A)'s order and remanded the matter to the jurisdictional AO for fresh adjudication under section 56(2)(x), directing the AO to consider stamp duty, additional stamp duty, registration charges, legal fees and other taxes/charges as part of the cost of acquisition when estimating fair market value. The AO must afford the assessee a proper opportunity of hearing and permit submission of supporting documentation. The assessee is directed to furnish all necessary details to the JA(O) for reconsideration. The appeal is allowed for statistical purposes and the original addition is vacated pending fresh determination by the AO.
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