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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Deduction for reinvestment of long-term capital gains into agricultural land is analysed with focus on whether a purchase constitutes a transfer for tax relief. The document reasons that where purchase consideration was paid, possession received, and the purchase deed ultimately registered, the transaction satisfies the legal attributes of transfer and purchase for claiming relief; consequently the reinvestment deduction is available. The decision rejects treating the sale proceeds as unexplained receipts and concludes that the purchasers entitlement to deduction accrues when the transfer takes effect, allowing the claim under the relevant deduction provision.
Deduction for reinvestment of long-term capital gains into agricultural land is analysed with focus on whether a purchase constitutes a transfer for tax relief. The document reasons that where purchase consideration was paid, possession received, and the purchase deed ultimately registered, the transaction satisfies the legal attributes of transfer and purchase for claiming relief; consequently the reinvestment deduction is available. The decision rejects treating the sale proceeds as unexplained receipts and concludes that the purchasers entitlement to deduction accrues when the transfer takes effect, allowing the claim under the relevant deduction provision.
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