Pharmaceutical promotion and transfer-pricing comparability principles limited disallowances, while uncorroborated search allegations and unsupported ...
Business expenditure substantiation supports scrap credits, statutory payments and expense claims, while depreciation requires proof of actual busines...
Where an assessee disputes stamp duty value under Section 43CA and the matter is referred to the DVO, the DVO valuation substitutes the stamp duty value for testing the safe harbour tolerance band. Applying that principle, the Tribunal found that in each impugned transaction the difference between the agreement value and the DVO valuation was below the prescribed 10% margin. As the variation remained within the permissible tolerance, the deeming fiction under Section 43CA could not be invoked and the addition could not survive; the addition was deleted.
Where an assessee disputes stamp duty value under Section 43CA and the matter is referred to the DVO, the DVO valuation substitutes the stamp duty value for testing the safe harbour tolerance band. Applying that principle, the Tribunal found that in each impugned transaction the difference between the agreement value and the DVO valuation was below the prescribed 10% margin. As the variation remained within the permissible tolerance, the deeming fiction under Section 43CA could not be invoked and the addition could not survive; the addition was deleted.
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