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 upheld the addition made under the head "Income from other sources" in respect of interest received under s.28 of the Land Acquisition Act, treating it as taxable u/s 56(2)(viii) read with s.145B(1) for the post-01.04.2010 assessment year in question. The agricultural land compensation itself remained exempt u/s 10(37), but the interest component was held separately chargeable on receipt basis. ITAT ruled that earlier Supreme Court jurisprudence characterising such interest as part of compensation applied only to the pre-amendment regime and cannot override the explicit charging provisions inserted by the Finance Act, 2010. Arguments based on Hari Singh, Braham Prakash and the per incuriam doctrine were rejected, and the High Court decisions upholding post-amendment taxability were followed. The assessee's appeal was dismissed.
ITAT upheld the addition made under the head "Income from other sources" in respect of interest received under s.28 of the Land Acquisition Act, treating it as taxable u/s 56(2)(viii) read with s.145B(1) for the post-01.04.2010 assessment year in question. The agricultural land compensation itself remained exempt u/s 10(37), but the interest component was held separately chargeable on receipt basis. ITAT ruled that earlier Supreme Court jurisprudence characterising such interest as part of compensation applied only to the pre-amendment regime and cannot override the explicit charging provisions inserted by the Finance Act, 2010. Arguments based on Hari Singh, Braham Prakash and the per incuriam doctrine were rejected, and the High Court decisions upholding post-amendment taxability were followed. The assessee's appeal was dismissed.
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