Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
Consideration received on surrender of tenancy rights was treated as arising from a capital asset, so its taxability had to be examined under Capital Gains. Even where the cost of acquisition was said to be unascertainable or nil, the receipt could not be re-characterised and taxed under the residuary head of Income from Other Sources. The Tribunal relied on the established principle that failure of capital gains computation does not permit shifting a capital receipt to a different head of income, and upheld deletion of the addition. The tenancy and surrender agreements were on record, with no adverse finding on their genuineness.
Consideration received on surrender of tenancy rights was treated as arising from a capital asset, so its taxability had to be examined under Capital Gains. Even where the cost of acquisition was said to be unascertainable or nil, the receipt could not be re-characterised and taxed under the residuary head of Income from Other Sources. The Tribunal relied on the established principle that failure of capital gains computation does not permit shifting a capital receipt to a different head of income, and upheld deletion of the addition. The tenancy and surrender agreements were on record, with no adverse finding on their genuineness.
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