Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
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LTCG - valuation of the property to the DVO - Valuation report given by the DVO cannot be ignored. Since the DVO himself valued the property which is less than the value adopted for the purpose of stamp duty and registration, the same should be adopted for the purpose of determining the full value of consideration received on transfer of capital asset for computing LTCG as laid down in Sec.50C(3)
LTCG - valuation of the property to the DVO - Valuation report given by the DVO cannot be ignored. Since the DVO himself valued the property which is less than the value adopted for the purpose of stamp duty and registration, the same should be adopted for the purpose of determining the full value of consideration received on transfer of capital asset for computing LTCG as laid down in Sec.50C(3)
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