Charitable sports promotion: sponsorship receipts alone did not defeat registration where funds supported tournaments and player development activitie...
Overdue associated-enterprise receivables: debt-free status defeated notional-interest adjustment, while employee stock-option costs qualified as busi...
Retrospective assessment-limitation amendments validate final orders while contemporaneous segment data governs transfer-pricing comparability and tol...
Transfer pricing adjustments must track international transactions, while unsupported AMP adjustments and unsuitable manufacturing comparables require...
Transfer-pricing adjustments must reflect functional comparability, working-capital effects, and avoid duplicating interest on associated-enterprise r...
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 4886 
