Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
Cancellation of the original allotment and a subsequent fresh allotment to a different flat broke the link with the 2012 transaction; the later registered agreement was treated as a new transaction, so adoption of the earlier valuation date was rejected. The cited precedent was distinguished on facts, and the claim to use the 2012 allotment date for stamp duty valuation was not accepted. On the alternative issue, once the stamp valuation adopted by the authority was disputed and supporting valuation material was filed, the Assessing Officer was required to obtain a DVO report before making any addition. The matter was restored for DVO reference and recomputation after hearing.
Cancellation of the original allotment and a subsequent fresh allotment to a different flat broke the link with the 2012 transaction; the later registered agreement was treated as a new transaction, so adoption of the earlier valuation date was rejected. The cited precedent was distinguished on facts, and the claim to use the 2012 allotment date for stamp duty valuation was not accepted. On the alternative issue, once the stamp valuation adopted by the authority was disputed and supporting valuation material was filed, the Assessing Officer was required to obtain a DVO report before making any addition. The matter was restored for DVO reference and recomputation after hearing.
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