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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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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