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 56(2)(x)(b), introduced by the Finance Act 2018 and applicable from Assessment Year 2019-20, operates prospectively. It cannot tax the difference between purchase consideration and stamp value where an immovable-property purchase agreement was executed in 2013 and substantial consideration was paid through banking channels before the provision was inserted. On those facts, the stamp-value-difference addition was deleted and the appellate order sustaining it was set aside.
Section 56(2)(x)(b), introduced by the Finance Act 2018 and applicable from Assessment Year 2019-20, operates prospectively. It cannot tax the difference between purchase consideration and stamp value where an immovable-property purchase agreement was executed in 2013 and substantial consideration was paid through banking channels before the provision was inserted. On those facts, the stamp-value-difference addition was deleted and the appellate order sustaining it was set aside.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
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