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 the assessee ineligible for exemption u/s 54/54F as the assessee already owned more than one independent residential house at the time of transfer, evidenced by three separate rentable residential units with independent kitchens in one building, rendering the claim barred at the threshold. The Tribunal rejected reliance on contrary case law as distinguishable. On unexplained cash deposits during demonetisation, ITAT accepted the assessee's explanation that deposits were sourced from earlier cash withdrawals, refundable rental security deposits and amounts received under a joint development agreement forming part of sale consideration, deleting the addition u/s 69A. Consequently, issues on tax rate u/s 115BBE were rendered infructuous. The appeal was partly allowed.
ITAT held the assessee ineligible for exemption u/s 54/54F as the assessee already owned more than one independent residential house at the time of transfer, evidenced by three separate rentable residential units with independent kitchens in one building, rendering the claim barred at the threshold. The Tribunal rejected reliance on contrary case law as distinguishable. On unexplained cash deposits during demonetisation, ITAT accepted the assessee's explanation that deposits were sourced from earlier cash withdrawals, refundable rental security deposits and amounts received under a joint development agreement forming part of sale consideration, deleting the addition u/s 69A. Consequently, issues on tax rate u/s 115BBE were rendered infructuous. The appeal was partly allowed.
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