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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Relief under s.54 was allowable despite a prior joint development arrangement and demolition, because the "transfer" was treated as occurring on execution of the later conveyances, and reinvestment in a residential house within the statutory window satisfied s.54(1); consequently, denial on the ground that the property had been demolished earlier was set aside. Deposit under the Capital Gains Accounts Scheme under s.54(2) was held inapplicable where the assessee had actually reinvested within time, and s.54 was not deniable merely because no "house property" income was returned, since the test is whether such income was assessable; relief under s.54 was granted. An alternate claim under s.54F was rejected for want of a properly pleaded claim and supporting facts; denial under s.54F was upheld - HC
Relief under s.54 was allowable despite a prior joint development arrangement and demolition, because the "transfer" was treated as occurring on execution of the later conveyances, and reinvestment in a residential house within the statutory window satisfied s.54(1); consequently, denial on the ground that the property had been demolished earlier was set aside. Deposit under the Capital Gains Accounts Scheme under s.54(2) was held inapplicable where the assessee had actually reinvested within time, and s.54 was not deniable merely because no "house property" income was returned, since the test is whether such income was assessable; relief under s.54 was granted. An alternate claim under s.54F was rejected for want of a properly pleaded claim and supporting facts; denial under s.54F was upheld - HC
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