Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
Consideration received for granting development rights under a redevelopment agreement was treated as capital gains because the payment was directly linked to transfer of valuable development rights, which are capital assets; mere retention of rights in the redeveloped premises did not negate the transfer, and the developer's accounting treatment was irrelevant. As the receipt was referable to transfer of a capital asset, it could not be assessed under the residuary head of income. On that basis, the related exemption for investment in REC bonds was allowed, subject to verification of the statutory conditions.
Consideration received for granting development rights under a redevelopment agreement was treated as capital gains because the payment was directly linked to transfer of valuable development rights, which are capital assets; mere retention of rights in the redeveloped premises did not negate the transfer, and the developer's accounting treatment was irrelevant. As the receipt was referable to transfer of a capital asset, it could not be assessed under the residuary head of income. On that basis, the related exemption for investment in REC bonds was allowed, subject to verification of the statutory conditions.
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