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 paid on a housing loan used to acquire immovable property was held to be a financial liability and not part of the "cost of acquisition" for capital gains purposes; it is deductible, if otherwise permissible, under the head "income from house property" as revenue expenditure, and cannot be capitalised into acquisition cost, resulting in rejection of the related grounds. On an amount paid for delayed possession sought to be treated as part of acquisition cost, the matter was correctly remitted for verification whether it was actually claimed in computation; if not claimed, no disallowance/addition could be made, and the appeal against remand was rejected. - ITAT
Interest paid on a housing loan used to acquire immovable property was held to be a financial liability and not part of the "cost of acquisition" for capital gains purposes; it is deductible, if otherwise permissible, under the head "income from house property" as revenue expenditure, and cannot be capitalised into acquisition cost, resulting in rejection of the related grounds. On an amount paid for delayed possession sought to be treated as part of acquisition cost, the matter was correctly remitted for verification whether it was actually claimed in computation; if not claimed, no disallowance/addition could be made, and the appeal against remand was rejected. - ITAT
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