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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Assessee entitled to deduction under 54F where the entire sale consideration was invested in purchase of a residential house within one year, notwithstanding that only part had been deposited in a capital gains account scheme before filing the return. Tribunal applied the principle that the legislative purpose is to ensure reinvestment of sale proceeds into residential property rather than formal deposit into the capital gains account scheme; consequently compliance is satisfied by actual investment within the prescribed period. Reliance was placed on the reasoning in K. Ramchandra Rao affirming substance over form for 54F relief.
Assessee entitled to deduction under 54F where the entire sale consideration was invested in purchase of a residential house within one year, notwithstanding that only part had been deposited in a capital gains account scheme before filing the return. Tribunal applied the principle that the legislative purpose is to ensure reinvestment of sale proceeds into residential property rather than formal deposit into the capital gains account scheme; consequently compliance is satisfied by actual investment within the prescribed period. Reliance was placed on the reasoning in K. Ramchandra Rao affirming substance over form for 54F relief.
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