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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Capital gains computation under section 50C: the property is recorded as agricultural/residential in revenue records, so circle rate characterisation must follow those records and the multiplicative factor of 1 applies even though the building was used commercially without sanction; deemed conversion cannot be presumed from unauthorized use until recognised by revenue authorities, so the assessing officer's application of factor 3 was contrary to revenue records and invalid, and the appellate authority's direction to apply factor 1 was affirmed by ITAT, resulting in the decision against the revenue.
Capital gains computation under section 50C: the property is recorded as agricultural/residential in revenue records, so circle rate characterisation must follow those records and the multiplicative factor of 1 applies even though the building was used commercially without sanction; deemed conversion cannot be presumed from unauthorized use until recognised by revenue authorities, so the assessing officer's application of factor 3 was contrary to revenue records and invalid, and the appellate authority's direction to apply factor 1 was affirmed by ITAT, resulting in the decision against the revenue.
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