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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Section 54 exemption was allowed for investment in more than one residential property, with the Tribunal accepting that the word "a" can encompass more than one house where supported by precedent. It also held that investments made after the due date for filing the income tax return could still be considered for exemption, even if not deposited in the capital gains scheme, and directed the Assessing Officer to allow relief on that basis. The result was that the assessee remained eligible for Section 54 relief on both the multiple-property investment and the delayed investment.
Section 54 exemption was allowed for investment in more than one residential property, with the Tribunal accepting that the word "a" can encompass more than one house where supported by precedent. It also held that investments made after the due date for filing the income tax return could still be considered for exemption, even if not deposited in the capital gains scheme, and directed the Assessing Officer to allow relief on that basis. The result was that the assessee remained eligible for Section 54 relief on both the multiple-property investment and the delayed investment.
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