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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Determination of acquisition year for Long-Term Capital Gains hinges on transfer effected by handing over possession in part performance; registration date does not shift the year of acquisition once possession and consideration were transferred, so the FY 1996-97 Cost Inflation Index applies. The tribunal rejects need for independent third party corroboration where no adverse material exists and accords evidentiary weight to the registered document. On deduction of construction cost, the tribunal applied the principle of consistency and parity among similarly placed co owners, directing that construction and improvement costs accepted in co owners' cases be allowed mutatis mutandis to the assessee.
Determination of acquisition year for Long-Term Capital Gains hinges on transfer effected by handing over possession in part performance; registration date does not shift the year of acquisition once possession and consideration were transferred, so the FY 1996-97 Cost Inflation Index applies. The tribunal rejects need for independent third party corroboration where no adverse material exists and accords evidentiary weight to the registered document. On deduction of construction cost, the tribunal applied the principle of consistency and parity among similarly placed co owners, directing that construction and improvement costs accepted in co owners' cases be allowed mutatis mutandis to the assessee.
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