Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...
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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