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 allotment-based acquisition of immovable property, the holding period was held to run from the allotment date where the allotment letter created substantive enforceable rights and substantial consideration had already been paid, so the transfer was taxable as long-term capital gain. The Tribunal also treated additional evidence as admitted once it had been sent for remand comments and considered on merits, and found a separate refusal to admit it self-contradictory. For the immovable-property addition, it accepted substantial compliance with the banking-channel condition, held that the stamp duty value as on the allotment date was the relevant benchmark, and restored the matter only for limited factual verification of that valuation.
On allotment-based acquisition of immovable property, the holding period was held to run from the allotment date where the allotment letter created substantive enforceable rights and substantial consideration had already been paid, so the transfer was taxable as long-term capital gain. The Tribunal also treated additional evidence as admitted once it had been sent for remand comments and considered on merits, and found a separate refusal to admit it self-contradictory. For the immovable-property addition, it accepted substantial compliance with the banking-channel condition, held that the stamp duty value as on the allotment date was the relevant benchmark, and restored the matter only for limited factual verification of that valuation.
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