Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
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For AY 2009-10, the pre-amendment position on reference to a Valuation Officer governed the computation of capital gains. Where the assessee adopted the fair market value of the property as on 01.04.1981 on the basis of a registered valuer's report, the Assessing Officer had no authority to make a reference merely to reduce that value. On that footing, the Valuation Officer's report was held irrelevant for recomputing long-term capital gains, and the resulting addition was deleted. The alternate contention on tolerance in sale consideration was not examined because the primary issue was ative.
For AY 2009-10, the pre-amendment position on reference to a Valuation Officer governed the computation of capital gains. Where the assessee adopted the fair market value of the property as on 01.04.1981 on the basis of a registered valuer's report, the Assessing Officer had no authority to make a reference merely to reduce that value. On that footing, the Valuation Officer's report was held irrelevant for recomputing long-term capital gains, and the resulting addition was deleted. The alternate contention on tolerance in sale consideration was not examined because the primary issue was ative.
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