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 10% tolerance band under the stamp valuation framework applies retrospectively as a curative measure, so no addition survived where the difference between agreement value and stamp duty value was only 2.3%. It also accepted that indexation of cost for flat allotment rights runs from the date of the agreement, since rights accrued on execution and not from the dates of later instalments, leading to deletion of the recomputed disallowance. For the unexplained investment issue, the Tribunal found factual verification was needed and remanded the matter to the Assessing Officer after granting adequate hearing.
The Tribunal held that the 10% tolerance band under the stamp valuation framework applies retrospectively as a curative measure, so no addition survived where the difference between agreement value and stamp duty value was only 2.3%. It also accepted that indexation of cost for flat allotment rights runs from the date of the agreement, since rights accrued on execution and not from the dates of later instalments, leading to deletion of the recomputed disallowance. For the unexplained investment issue, the Tribunal found factual verification was needed and remanded the matter to the Assessing Officer after granting adequate hearing.
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