Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
Under a joint development agreement, transfer for capital-gains purposes may occur when the developer is permitted to enter the land and undertake development in part performance of the agreement, regardless of a recital that possession was not delivered. Receipt or sale of allotted flats is treated as a separate taxable stage and does not defer the transfer of land and development rights. Consideration for the landowner is determined by the stamp duty value of the built-up area received, rather than the developer's construction cost, with applicable indexed cost and expense deductions. Under the then applicable law, multiple allotted residential flats may qualify collectively as a residential house for exemption under sections 54 and 54F.
Under a joint development agreement, transfer for capital-gains purposes may occur when the developer is permitted to enter the land and undertake development in part performance of the agreement, regardless of a recital that possession was not delivered. Receipt or sale of allotted flats is treated as a separate taxable stage and does not defer the transfer of land and development rights. Consideration for the landowner is determined by the stamp duty value of the built-up area received, rather than the developer's construction cost, with applicable indexed cost and expense deductions. Under the then applicable law, multiple allotted residential flats may qualify collectively as a residential house for exemption under sections 54 and 54F.
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