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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Compensation received on compulsory acquisition of agricultural land under the National Highways Act was held to be exempt from tax. Although the assessee had wrongly reflected the receipt as exempt agricultural income, the Tribunal accepted the award and payment records showing that the amount represented statutory land acquisition compensation with interest. The authorities had already treated the interest component as exempt, but wrongly assessed the compensation component as income from other sources. Relying on CBDT Circular No. 36 of 2016, section 96 of the RFCTLARR Act, and the decisions in Sanjay Kumar Baid and NHAI v. P. Nagaraju, the Tribunal held that the exemption extended to acquisition under the National Highways Act and deleted the addition.
Compensation received on compulsory acquisition of agricultural land under the National Highways Act was held to be exempt from tax. Although the assessee had wrongly reflected the receipt as exempt agricultural income, the Tribunal accepted the award and payment records showing that the amount represented statutory land acquisition compensation with interest. The authorities had already treated the interest component as exempt, but wrongly assessed the compensation component as income from other sources. Relying on CBDT Circular No. 36 of 2016, section 96 of the RFCTLARR Act, and the decisions in Sanjay Kumar Baid and NHAI v. P. Nagaraju, the Tribunal held that the exemption extended to acquisition under the National Highways Act and deleted the addition.
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