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 43CA applies only to transfer of land or building or both held as stock-in-trade, and its deeming fiction cannot be extended to TDR/FSI rights. Because transferable development rights are intangible development rights and not land or building per se, adoption of stamp duty value for their transfer was held impermissible. The addition made under section 43CA was therefore deleted, and the Revenue's appeal failed.
Section 43CA applies only to transfer of land or building or both held as stock-in-trade, and its deeming fiction cannot be extended to TDR/FSI rights. Because transferable development rights are intangible development rights and not land or building per se, adoption of stamp duty value for their transfer was held impermissible. The addition made under section 43CA was therefore deleted, and the Revenue's appeal failed.
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