Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
