Transfer pricing adjustments for software services, corporate guarantees, expense characterisation and foreign tax credit affirmed under arm's length ...
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Interest received on enhanced compensation for compulsory acquisition of rural agricultural land, though described as interest under s.28 of the Land Acquisition Act, was held to be taxable as "Income from Other Sources" under s.56(2)(viii) and chargeable in the year of receipt under s.145B(1), rather than forming part of exempt compensation under s.10(37). The plea that such interest is inseparable from compensation and therefore exempt was rejected as contrary to the statutory scheme and the settled co-ordinate bench view in an identical fact pattern. Consequently, the addition was sustained and the appeal was dismissed. - ITAT
Interest received on enhanced compensation for compulsory acquisition of rural agricultural land, though described as interest under s.28 of the Land Acquisition Act, was held to be taxable as "Income from Other Sources" under s.56(2)(viii) and chargeable in the year of receipt under s.145B(1), rather than forming part of exempt compensation under s.10(37). The plea that such interest is inseparable from compensation and therefore exempt was rejected as contrary to the statutory scheme and the settled co-ordinate bench view in an identical fact pattern. Consequently, the addition was sustained and the appeal was dismissed. - ITAT
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