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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Conversion of tenancy right into ownership requires treating the market value of the ownership interest received in exchange as the cost of acquisition for capital gains computation; the tribunal directs the AO to use the fair market value of the flats acquired under the development agreement dated 22.07.2008 as cost of acquisition and to re-compute capital gains accordingly. The tribunal rejects the taxpayer's claims for capital gains exemptions under reinvestment provisions because supporting documents were not furnished, and therefore those exemption claims fail.
Conversion of tenancy right into ownership requires treating the market value of the ownership interest received in exchange as the cost of acquisition for capital gains computation; the tribunal directs the AO to use the fair market value of the flats acquired under the development agreement dated 22.07.2008 as cost of acquisition and to re-compute capital gains accordingly. The tribunal rejects the taxpayer's claims for capital gains exemptions under reinvestment provisions because supporting documents were not furnished, and therefore those exemption claims fail.
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