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...
For property devolving on a beneficiary upon dissolution of a private family trust, the previous owner's holding period must be included where the previous owner's cost is adopted under section 49(1). Explanation 1(b) to section 2(42A) requires that deemed holding period to determine whether the asset is long-term; the properties therefore qualify as long-term capital assets. The same holding period applies to indexed cost of acquisition, which must be computed from the year in which the previous owner first held the property. Gains on the sale of such devolved immovable properties are accordingly taxable as long-term capital gains, and the related addition was deleted.
For property devolving on a beneficiary upon dissolution of a private family trust, the previous owner's holding period must be included where the previous owner's cost is adopted under section 49(1). Explanation 1(b) to section 2(42A) requires that deemed holding period to determine whether the asset is long-term; the properties therefore qualify as long-term capital assets. The same holding period applies to indexed cost of acquisition, which must be computed from the year in which the previous owner first held the property. Gains on the sale of such devolved immovable properties are accordingly taxable as long-term capital gains, and the related addition was deleted.
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