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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A composite property used partly for residence and partly for commercial activity was treated as eligible for section 54 relief to the extent of the residential portion. The Tribunal held that the residential component could not be ignored merely because the sale agreement described the property as commercial, and directed apportionment of sale consideration relating to the residential floors before granting exemption. On the addition under section 56(2)(vii), it held that where the assessee disputed the stamp valuation, the Assessing Officer should have referred the matter to the DVO instead of directly taxing the difference. The valuation issue was remitted for fresh decision.
A composite property used partly for residence and partly for commercial activity was treated as eligible for section 54 relief to the extent of the residential portion. The Tribunal held that the residential component could not be ignored merely because the sale agreement described the property as commercial, and directed apportionment of sale consideration relating to the residential floors before granting exemption. On the addition under section 56(2)(vii), it held that where the assessee disputed the stamp valuation, the Assessing Officer should have referred the matter to the DVO instead of directly taxing the difference. The valuation issue was remitted for fresh decision.
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