SEZ-unit profit deduction covers voluntary transfer-pricing adjustments, while exempt-income costs, foreign-exchange loss and ITeS comparables are exa...
Infrastructure-development deduction remains available to EPC contractors when substantive statutory conditions outweigh contractor labels in agreemen...
Section 50C does not extend to relinquishment of an unregistered contractual right to seek specific performance of an agreement to sell land. Where no sale deed is registered in the transferee's favour and the vendor remains owner, the relinquished right is a capital asset comprising a contractual remedy, not land or building. The deeming fiction is confined to transfers of land or building and cannot be enlarged to cover such rights. A registered leasehold interest was distinguished because it confers possessory and enjoyment rights in rem. The recomputation of long-term capital gain under section 50C and the resulting addition were deleted.
Section 50C does not extend to relinquishment of an unregistered contractual right to seek specific performance of an agreement to sell land. Where no sale deed is registered in the transferee's favour and the vendor remains owner, the relinquished right is a capital asset comprising a contractual remedy, not land or building. The deeming fiction is confined to transfers of land or building and cannot be enlarged to cover such rights. A registered leasehold interest was distinguished because it confers possessory and enjoyment rights in rem. The recomputation of long-term capital gain under section 50C and the resulting addition were deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4888 
