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...
Delayed conveyance of land and building to a housing society, where the promoter had a pre-existing statutory and contractual duty to convey, does not constitute a fresh receipt of immovable property for inadequate consideration merely because registration occurred later. The conveyance perfected legal title and transferred remaining reversionary and leasehold interests in property already possessed and beneficially enjoyed by the society and its members. Intervening disputes explaining delayed registration did not alter the bona fide antecedent arrangement. Consequently, the difference between stamp duty value and settlement consideration was not taxable under section 56(2)(x), and the related addition was deleted.
Delayed conveyance of land and building to a housing society, where the promoter had a pre-existing statutory and contractual duty to convey, does not constitute a fresh receipt of immovable property for inadequate consideration merely because registration occurred later. The conveyance perfected legal title and transferred remaining reversionary and leasehold interests in property already possessed and beneficially enjoyed by the society and its members. Intervening disputes explaining delayed registration did not alter the bona fide antecedent arrangement. Consequently, the difference between stamp duty value and settlement consideration was not taxable under section 56(2)(x), and the related addition was deleted.
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