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...
A later registration of a conveyance deed does not create a separate capital-gains charge where the underlying land was already included in a slump sale of the entire business undertaking and the resulting gain was taxed under section 50B in an earlier assessment year. The Bhiwandi land formed part of the assets transferred for lump-sum consideration, and the later deed was treated as formalising title rather than effecting an independent transfer. Accordingly, isolating that land and taxing the same transfer again in a subsequent year would result in double taxation, and the later long-term capital-gain addition was deleted. A decision concerning an individual immovable-property transfer was distinguished as factually different from a slump sale of an undertaking.
A later registration of a conveyance deed does not create a separate capital-gains charge where the underlying land was already included in a slump sale of the entire business undertaking and the resulting gain was taxed under section 50B in an earlier assessment year. The Bhiwandi land formed part of the assets transferred for lump-sum consideration, and the later deed was treated as formalising title rather than effecting an independent transfer. Accordingly, isolating that land and taxing the same transfer again in a subsequent year would result in double taxation, and the later long-term capital-gain addition was deleted. A decision concerning an individual immovable-property transfer was distinguished as factually different from a slump sale of an undertaking.
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