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...
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.
Note: It is a system-generated summary and is for quick reference only.