Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
Fake AI-generated precedents vitiate adjudication, with unverified citations contaminating the decision-making process and undermining the rule of law...
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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