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 order of CIT(A) allowing assessee's deduction under s.54F in respect of long-term capital gains from sale of artwork/painting. The Tribunal held that, on the date of transfer, the assessee was the owner of only one residential house, as Villa Nos. 13 and 14 were still under construction and not available for occupation, and were subsequently treated and taxed as business assets on sale. Consequently, the proviso to s.54F, barring relief where more than one residential house is owned, was inapplicable. The disallowance made by the Assessing Officer was set aside and Revenue's appeal was dismissed.
ITAT upheld the order of CIT(A) allowing assessee's deduction under s.54F in respect of long-term capital gains from sale of artwork/painting. The Tribunal held that, on the date of transfer, the assessee was the owner of only one residential house, as Villa Nos. 13 and 14 were still under construction and not available for occupation, and were subsequently treated and taxed as business assets on sale. Consequently, the proviso to s.54F, barring relief where more than one residential house is owned, was inapplicable. The disallowance made by the Assessing Officer was set aside and Revenue's appeal was dismissed.
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