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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Deduction under the capital gains exemption for purchase of a new residential property was allowed where the property was registered in a sister's name but the assessee paid the booking advance and entire purchase consideration from his bank accounts, produced provisional allotment, a memorandum of understanding, confirmation from the sister that registration was for convenience, a subsequent gift deed and municipal records; the tribunal noted that liberal interpretation commonly afforded to purchases by spouse or unmarried children does not automatically extend to other relatives, but on the documentary chain and source-of-funds the exemption's conditions were satisfied and the disallowance was deleted.
Deduction under the capital gains exemption for purchase of a new residential property was allowed where the property was registered in a sister's name but the assessee paid the booking advance and entire purchase consideration from his bank accounts, produced provisional allotment, a memorandum of understanding, confirmation from the sister that registration was for convenience, a subsequent gift deed and municipal records; the tribunal noted that liberal interpretation commonly afforded to purchases by spouse or unmarried children does not automatically extend to other relatives, but on the documentary chain and source-of-funds the exemption's conditions were satisfied and the disallowance was deleted.
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