Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
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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