Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
Automated Free Sale and Commerce Certificates enable paperless processing while retaining risk-based manual verification for selected exporter applica...
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Long Term Capital Gain u/s 45 - transfer u/s 2(47) - non registration of agreement cannot lead to the conclusion that provision of section 2(47) (v) is not applicable - It is the members who are owning the plots and the Society was only a facilitator. It becomes clear from the JDA that payment for consideration was to be made to an individual plot holder and in fact consideration was mentioned in terms of per Member. - Capital gain is taxable in the hands of members - AT
Long Term Capital Gain u/s 45 - transfer u/s 2(47) - non registration of agreement cannot lead to the conclusion that provision of section 2(47) (v) is not applicable - It is the members who are owning the plots and the Society was only a facilitator. It becomes clear from the JDA that payment for consideration was to be made to an individual plot holder and in fact consideration was mentioned in terms of per Member. - Capital gain is taxable in the hands of members - AT
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