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...
Actual and continuous agricultural operations are not a mandatory statutory condition under section 2(14)(iii) where land is agricultural in character and lies beyond prescribed municipal limits. The ITAT noted that this provision follows an objective test based on municipal limits, population and urban proximity, unlike sections 54B and 10(37), and that actual cultivation is only an evidentiary factor, not the sole or independent test. On the facts, the land remained agricultural in records, was outside municipal limits and a no-development zone, and the capital gains addition was deleted.
Actual and continuous agricultural operations are not a mandatory statutory condition under section 2(14)(iii) where land is agricultural in character and lies beyond prescribed municipal limits. The ITAT noted that this provision follows an objective test based on municipal limits, population and urban proximity, unlike sections 54B and 10(37), and that actual cultivation is only an evidentiary factor, not the sole or independent test. On the facts, the land remained agricultural in records, was outside municipal limits and a no-development zone, and the capital gains addition was deleted.
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