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 assessee's appeal, holding that the restriction under s.112A(6) on claiming rebate u/s 87A applies only to Long-Term Equity Capital Gains covered by s.112A(1)(ii), and not to Long-Term Debt Capital Gains, which are governed by s.112. As the assessee's tax on debt LTCG and on other normal income each exceeded the rebate threshold of Rs. 25,000, the assessee was held entitled to the full rebate of Rs. 25,000 u/s 87A. CPC was directed to recompute the tax liability accordingly in line with this interpretation.
ITAT allowed the assessee's appeal, holding that the restriction under s.112A(6) on claiming rebate u/s 87A applies only to Long-Term Equity Capital Gains covered by s.112A(1)(ii), and not to Long-Term Debt Capital Gains, which are governed by s.112. As the assessee's tax on debt LTCG and on other normal income each exceeded the rebate threshold of Rs. 25,000, the assessee was held entitled to the full rebate of Rs. 25,000 u/s 87A. CPC was directed to recompute the tax liability accordingly in line with this interpretation.
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