Verification of intangible software expenditure and duplicated disallowances requires record-based reassessment before depreciation and income computa...
Cash receipt aggregation requires a single transaction, event or occasion; separate partner capital contributions cannot attract cash-receipt penaltie...
GAAR requires the Revenue to establish an arrangement, a main purpose of obtaining a tax benefit, and at least one further statutory condition before treating a transaction as an impermissible avoidance arrangement. Arm's-length purchases and sales of listed shares through a recognised stock exchange at market prices, without taxpayer control over counterparties or market outcomes, lack the concerted or pre-ordained steps required for that characterisation. A commercially sustained short-term capital loss is not a tax benefit merely because it may be set off against long-term capital gains; the set-off forms part of annual-income computation. The GAAR directions were set aside and the loss set-off was allowed.
GAAR requires the Revenue to establish an arrangement, a main purpose of obtaining a tax benefit, and at least one further statutory condition before treating a transaction as an impermissible avoidance arrangement. Arm's-length purchases and sales of listed shares through a recognised stock exchange at market prices, without taxpayer control over counterparties or market outcomes, lack the concerted or pre-ordained steps required for that characterisation. A commercially sustained short-term capital loss is not a tax benefit merely because it may be set off against long-term capital gains; the set-off forms part of annual-income computation. The GAAR directions were set aside and the loss set-off was allowed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4923 
