Building-plan sanction charges require statutory authority; unauthorised fees and GST were quashed, while labour cess must follow prescribed collectio...
Pure-agent exclusion fails where hotel booking facilitators receive third-party services themselves, making entire customer consideration taxable as r...
Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
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Amendments to the section 50C tolerance band were treated as curative and beneficial, intended to reduce hardship from minor differences between declared sale consideration and stamp duty value. Applying the retrospective benefit, the Tribunal held that where the stamp duty value did not exceed 110% of the actual consideration, the deeming fiction under section 50C could not substitute the declared price. The actual sale consideration was therefore accepted for capital gains computation and the addition was deleted.
Amendments to the section 50C tolerance band were treated as curative and beneficial, intended to reduce hardship from minor differences between declared sale consideration and stamp duty value. Applying the retrospective benefit, the Tribunal held that where the stamp duty value did not exceed 110% of the actual consideration, the deeming fiction under section 50C could not substitute the declared price. The actual sale consideration was therefore accepted for capital gains computation and the addition was deleted.
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