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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Where a capital asset devolved on the assessee by succession or trust devolution, the period for which the asset was held by the previous owner/trust is to be included in computing holding period, making the asset a long-term capital asset. The Tribunal upheld allowance of exemption for investment in specified bonds, finding no material contradicting compliance with the bond-investment timing. Claim under the residential-house reinvestment exemption required actual purchase evidence; only an agreement was produced, so the matter was remanded to the Assessing Officer to verify execution of a registered conveyance/purchase deed within the statutory period and decide after hearing the assessee.
Where a capital asset devolved on the assessee by succession or trust devolution, the period for which the asset was held by the previous owner/trust is to be included in computing holding period, making the asset a long-term capital asset. The Tribunal upheld allowance of exemption for investment in specified bonds, finding no material contradicting compliance with the bond-investment timing. Claim under the residential-house reinvestment exemption required actual purchase evidence; only an agreement was produced, so the matter was remanded to the Assessing Officer to verify execution of a registered conveyance/purchase deed within the statutory period and decide after hearing the assessee.
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