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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Long-term capital loss claimed on sale of shares was contested by the assessing officer for lack of documentary proof and questioned valuation; the tribunal found that the assessee produced an independent valuation and net asset value showed sale prices exceeded NAV, and the revenue failed to produce alternative valuation or rebuttal during assessment, appeal or remand proceedings, entitling the assessee to recognition of the LTCL. The AOs selective acceptance of identical losses elsewhere and failure to undertake or furnish its own valuation led to upholding the appellate authoritys allowance of the loss.
Long-term capital loss claimed on sale of shares was contested by the assessing officer for lack of documentary proof and questioned valuation; the tribunal found that the assessee produced an independent valuation and net asset value showed sale prices exceeded NAV, and the revenue failed to produce alternative valuation or rebuttal during assessment, appeal or remand proceedings, entitling the assessee to recognition of the LTCL. The AOs selective acceptance of identical losses elsewhere and failure to undertake or furnish its own valuation led to upholding the appellate authoritys allowance of the loss.
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