Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Section 56(2)(vii)(b) does not apply to an HUF where documentary evidence shows that immovable property was acquired by its Karta in an individual capacity. The sale agreement, patta and encumbrance certificate supported individual ownership, while an erroneous reference to the HUF PAN in the sale deed did not establish that the HUF funded or owned the property. The addition based on the difference between stamp-duty value and consideration was therefore deleted. Documents considered by the appellate authority were already furnished during reassessment, so their consideration did not constitute admission of additional evidence under Rule 46A.
Section 56(2)(vii)(b) does not apply to an HUF where documentary evidence shows that immovable property was acquired by its Karta in an individual capacity. The sale agreement, patta and encumbrance certificate supported individual ownership, while an erroneous reference to the HUF PAN in the sale deed did not establish that the HUF funded or owned the property. The addition based on the difference between stamp-duty value and consideration was therefore deleted. Documents considered by the appellate authority were already furnished during reassessment, so their consideration did not constitute admission of additional evidence under Rule 46A.
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