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...
On sale of redeveloped premises received in exchange for surrendered tenancy rights, the stated legal position is that the property was not acquired for nil cost merely because no cash changed hands. Valuable tenancy rights are themselves a capital asset, so their fair market value on surrender can be taken as the cost of acquisition for computing capital gains on the later transfer of the premises received in exchange. Treating the cost as nil was said to tax gross sale proceeds rather than real gain. The matter was to be recomputed on that basis, including whether the resulting gain was short-term or long-term by reference to the holding period.
On sale of redeveloped premises received in exchange for surrendered tenancy rights, the stated legal position is that the property was not acquired for nil cost merely because no cash changed hands. Valuable tenancy rights are themselves a capital asset, so their fair market value on surrender can be taken as the cost of acquisition for computing capital gains on the later transfer of the premises received in exchange. Treating the cost as nil was said to tax gross sale proceeds rather than real gain. The matter was to be recomputed on that basis, including whether the resulting gain was short-term or long-term by reference to the holding period.
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