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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Vacant unsold flats and shops held as stock-in-trade were treated as taxable under the head income from house property on a notional annual letting value basis, with computation required to follow municipal rateable value principles rather than an ad hoc percentage of investment. Unsupported business promotion expenditure was disallowed because no bills, vouchers or other documentary evidence were produced. The addition under section 43CA was deleted for assessment year 2017-18 because the variation between consideration and stamp valuation fell within the applicable tolerance band, which was held to apply retrospectively as a curative measure.
Vacant unsold flats and shops held as stock-in-trade were treated as taxable under the head income from house property on a notional annual letting value basis, with computation required to follow municipal rateable value principles rather than an ad hoc percentage of investment. Unsupported business promotion expenditure was disallowed because no bills, vouchers or other documentary evidence were produced. The addition under section 43CA was deleted for assessment year 2017-18 because the variation between consideration and stamp valuation fell within the applicable tolerance band, which was held to apply retrospectively as a curative measure.
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