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Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
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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