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...
Unsupported estimation of indexed acquisition and construction or improvement costs cannot sustain capital-gains additions where neither the taxpayers' claims nor the Assessing Officer's adopted land and construction rates are supported by evidence. The reported tribunal decision deleted the resulting cost adjustments in all appeals. For section 54F, acquisition of a new residential property within the statutory period preserves the exemption despite non-deposit of interim unutilised gains in the Capital Gains Account Scheme, treating that omission as procedural. Exemption was allowed for investments made within time, but remained unavailable where the residential-property investment itself occurred beyond the prescribed period.
Unsupported estimation of indexed acquisition and construction or improvement costs cannot sustain capital-gains additions where neither the taxpayers' claims nor the Assessing Officer's adopted land and construction rates are supported by evidence. The reported tribunal decision deleted the resulting cost adjustments in all appeals. For section 54F, acquisition of a new residential property within the statutory period preserves the exemption despite non-deposit of interim unutilised gains in the Capital Gains Account Scheme, treating that omission as procedural. Exemption was allowed for investments made within time, but remained unavailable where the residential-property investment itself occurred beyond the prescribed period.
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