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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Property received pursuant to a family settlement was held not to constitute a 'transfer' under the definition of transfer and therefore not taxable as deemed income under the provision addressing property received without consideration. The tribunal accepted that the gift deed merely formalised title vesting between members who constituted an HUF, facts which the AO did not contest and which the CIT(A) found established. Consequence: the gift was treated as the formal execution of a family settlement, exempting it from being treated as taxable deemed income.
Property received pursuant to a family settlement was held not to constitute a 'transfer' under the definition of transfer and therefore not taxable as deemed income under the provision addressing property received without consideration. The tribunal accepted that the gift deed merely formalised title vesting between members who constituted an HUF, facts which the AO did not contest and which the CIT(A) found established. Consequence: the gift was treated as the formal execution of a family settlement, exempting it from being treated as taxable deemed income.
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