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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Transfer of an immovable residential property under a redevelopment agreement constituted a transfer of a capital asset in kind where the owners received constructed floors, an undivided share of land and cash. The ruling applies the principle that indexed cost of acquisition/construction is allowable over the entire transferred property and cannot be confined to the fractional undivided share corresponding to constructed area. The owners were held eligible for the deduction for reinvestment in residential property despite one floor being allotted to the developer; the assessing officer's disallowance of indexation was deleted and the officer directed to verify computation of the deduction.
Transfer of an immovable residential property under a redevelopment agreement constituted a transfer of a capital asset in kind where the owners received constructed floors, an undivided share of land and cash. The ruling applies the principle that indexed cost of acquisition/construction is allowable over the entire transferred property and cannot be confined to the fractional undivided share corresponding to constructed area. The owners were held eligible for the deduction for reinvestment in residential property despite one floor being allotted to the developer; the assessing officer's disallowance of indexation was deleted and the officer directed to verify computation of the deduction.
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