Transfer Pricing Officer jurisdiction is transaction-specific, excluding permanent establishment determinations and requiring independent assessment o...
Rental income valuation requires credible local comparables; family-business salary and commercially expedient unsecured-loan interest remained deduct...
Section 50C(1)'s proviso permits stamp-duty valuation on the date consideration was fixed rather than the registration date where the two dates differ. In a rehabilitation-related land transfer, statutory proceedings, resolutions, banking-channel advance receipt and a sanctioned scheme may collectively establish that consideration crystallised before registration, even without a conventional sale agreement. Later increases in guideline value or stamp-authority valuation cannot retrospectively replace that agreed consideration absent independent evidence of higher fair market value. The beneficial proviso operates retrospectively to relieve hardship. Accordingly, valuation applicable when consideration was fixed was adopted and the long-term capital gains addition was deleted.
Section 50C(1)'s proviso permits stamp-duty valuation on the date consideration was fixed rather than the registration date where the two dates differ. In a rehabilitation-related land transfer, statutory proceedings, resolutions, banking-channel advance receipt and a sanctioned scheme may collectively establish that consideration crystallised before registration, even without a conventional sale agreement. Later increases in guideline value or stamp-authority valuation cannot retrospectively replace that agreed consideration absent independent evidence of higher fair market value. The beneficial proviso operates retrospectively to relieve hardship. Accordingly, valuation applicable when consideration was fixed was adopted and the long-term capital gains addition was deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4888 
