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...
Transferable development rights received in exchange for surrendering land and building to a municipal authority have an ascertainable cost of acquisition: the cost attributable to the surrendered property. Their subsequent cash sale is therefore chargeable as capital gains, unlike self-generated development rights arising without transfer of an identified asset. Where a scrutiny notice merely identifies a refund claim for verification and does not specify limited scrutiny, the assessment may extend to the taxability of such rights. Non-taxation of similar receipts in another taxpayer's assessment does not create parity or estoppel against correct application of tax law. Capital gains must be recomputed after allowing the attributable acquisition cost.
Transferable development rights received in exchange for surrendering land and building to a municipal authority have an ascertainable cost of acquisition: the cost attributable to the surrendered property. Their subsequent cash sale is therefore chargeable as capital gains, unlike self-generated development rights arising without transfer of an identified asset. Where a scrutiny notice merely identifies a refund claim for verification and does not specify limited scrutiny, the assessment may extend to the taxability of such rights. Non-taxation of similar receipts in another taxpayer's assessment does not create parity or estoppel against correct application of tax law. Capital gains must be recomputed after allowing the attributable acquisition cost.
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