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 under s.28 of the Land Acquisition Act on enhanced compensation for compulsory acquisition of agricultural land was held taxable as "income from other sources" under s.56(2)(viii) read with s.145B(1), as the statutory language is clear and mandates such tax treatment; consequentially, deduction under s.57(iv) applies while recomputing such interest. The claim of exemption under s.10(37) was rejected because that provision covers only "compensation" for compulsory acquisition and does not extend to "interest on compensation/enhanced compensation." The appellate direction to recompute interest under s.56(2)(viii) with s.57(iv) deduction was upheld and the assessee's grounds were dismissed - ITAT
Interest received under s.28 of the Land Acquisition Act on enhanced compensation for compulsory acquisition of agricultural land was held taxable as "income from other sources" under s.56(2)(viii) read with s.145B(1), as the statutory language is clear and mandates such tax treatment; consequentially, deduction under s.57(iv) applies while recomputing such interest. The claim of exemption under s.10(37) was rejected because that provision covers only "compensation" for compulsory acquisition and does not extend to "interest on compensation/enhanced compensation." The appellate direction to recompute interest under s.56(2)(viii) with s.57(iv) deduction was upheld and the assessee's grounds were dismissed - ITAT
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