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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Eligibility for rebate under section 87A was contested for tax components including shortterm capital gains taxed at special rates, longterm capital gains, and tax on transfer of virtual digital assets. The tribunal found that the statutory language and existing precedents permit rebate against tax on shortterm capital gains taxed under the special rate provision, and directed allowance of the rebate (Rs. 13,320) with recomputation of tax. The tribunal rejected the claim for rebate against tax on income from transfer of virtual digital assets, leaving that element unaffected. The assessee had opted for the new tax regime; a prospective legislative amendment clarified intent but did not alter the outcome for the year in question.
Eligibility for rebate under section 87A was contested for tax components including shortterm capital gains taxed at special rates, longterm capital gains, and tax on transfer of virtual digital assets. The tribunal found that the statutory language and existing precedents permit rebate against tax on shortterm capital gains taxed under the special rate provision, and directed allowance of the rebate (Rs. 13,320) with recomputation of tax. The tribunal rejected the claim for rebate against tax on income from transfer of virtual digital assets, leaving that element unaffected. The assessee had opted for the new tax regime; a prospective legislative amendment clarified intent but did not alter the outcome for the year in question.
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