COMPENSATION FOR BUSINESS CLOSURE – WHETHER OPERATING OR NON-OPERATING FOR PLI COMPUTATION

Rule 10B of Income Tax Rules provides methodology for computation of ALP.  Under TNMM, ‘net profit’ is used as benchmark for ALP computation.  Rule 10B(1)(e)(i) provides for considering “net profit margin realised by the enterprise from an international transaction or SDT entered into with an associated enterprise”.  Rule 10B(1)(e)(ii) provides for computation of ‘net profit […]

DISPUTED TELEPHONE PAYMENT – WHETHER OPERATING OR NON-OPERATING FOR PLI COMPUTATION

Rule 10B of Income Tax Rules provides methodology for computation of ALP.  Under TNMM, ‘net profit’ is used as benchmark for ALP computation.  Rule 10B(1)(e)(i) provides for considering “net profit margin realised by the enterprise from an international transaction or SDT entered into with an associated enterprise”.  Rule 10B(1)(e)(ii) provides for computation of ‘net profit […]

EXEMPTION U/S 54/54F – MEANING OF “COST OF RESIDENTIAL HOUSE”

Under section 54 and 54F provides for exemption from Long Term Capital Gains for certain investments.  Under section 54, the Assessee should appropriate the capital gains towards “cost of the residential house purchased or constructed”.  Similarly, under section 54F, the assessee should appropriate the net sale consideration towards “cost of new asset (purchased or constructed, […]

SUPREME COURT DECISION IN THE CASE OF ISHIKAWAJIMA-HARIMA HEAVY INDUSTRIES LTD V DIT [2007] 288 ITR 408 (SC) / (2007) 3 SCC 481 – ANALYSIS AND LEARNINGS

Background The Assessee is a company incorporated in Japan.  It is engaged, inter alia, in the business of construction of storage tanks as also engineering etc.  It formed a consortium with various parties and entered into an Agreement with Petronet LNG Limited (“LNG Petronet”) on 19-1-2001 for setting up a Liquefied Natural Gas (LNG) receiving, […]

DIVIDEND INCOME – WHETHER OPERATING OR NON-OPERATING FOR PLI COMPUTATION

Rule 10B of Income Tax Rules provides methodology for computation of ALP.  Under TNMM, ‘net profit’ is used as benchmark for ALP computation.  Rule 10B(1)(e)(i) provides for considering “net profit margin realised by the enterprise from an international transaction or SDT entered into with an associated enterprise”.  Rule 10B(1)(e)(ii) provides for computation of ‘net profit […]

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