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...
Capital gains exemption through a Capital Gains Account Scheme deposit is discussed as available where bank records and a certificate establish that the deposit was made under the prescribed scheme; the section 54 disallowance was deleted. The taxability of gains from sale of rural agricultural land depends on verifying whether the land was within eight kilometres of municipal limits; the matter was remitted for factual verification and fresh adjudication. Indexation must be allowed when computing capital gains on the residential property, requiring consequential recomputation after resolution of the exemption claim.
Capital gains exemption through a Capital Gains Account Scheme deposit is discussed as available where bank records and a certificate establish that the deposit was made under the prescribed scheme; the section 54 disallowance was deleted. The taxability of gains from sale of rural agricultural land depends on verifying whether the land was within eight kilometres of municipal limits; the matter was remitted for factual verification and fresh adjudication. Indexation must be allowed when computing capital gains on the residential property, requiring consequential recomputation after resolution of the exemption claim.
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