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...
The Tribunal held that the enhancement of the stamp duty valuation tolerance band from 5% to 10% was a curative, beneficial amendment applicable to A.Y. 2018-19, because it only relaxed the rigour of a deeming provision and did not create a new charge or fresh burden. It further held that the deeming fiction under section 56(2)(x)(b)(B) could not be invoked where the difference between the purchase consideration and the stamp duty value was 7.44%, being within the 10% band. The addition was deleted.
The Tribunal held that the enhancement of the stamp duty valuation tolerance band from 5% to 10% was a curative, beneficial amendment applicable to A.Y. 2018-19, because it only relaxed the rigour of a deeming provision and did not create a new charge or fresh burden. It further held that the deeming fiction under section 56(2)(x)(b)(B) could not be invoked where the difference between the purchase consideration and the stamp duty value was 7.44%, being within the 10% band. The addition was deleted.
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