Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...
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Addition u/s. 56(2)(vii) - difference between the stamp duty guideline value and purchase consideration i.e. 50 percent u/s 56(2)(vii)(b) - the Department cannot be allowed a second inning by sending the matter back to the Assessing Officer enabling the revenue to fill the lacunae and shortcomings and further putting the assessee to face a re-trail for no fault of him and to prove before the Assessing Officer that the sale consideration was the fair market value of the property purchased by him - We delete the addition made by the AO u/s. 56(2)(vii)(b) of the Act. - AT
Addition u/s. 56(2)(vii) - difference between the stamp duty guideline value and purchase consideration i.e. 50 percent u/s 56(2)(vii)(b) - the Department cannot be allowed a second inning by sending the matter back to the Assessing Officer enabling the revenue to fill the lacunae and shortcomings and further putting the assessee to face a re-trail for no fault of him and to prove before the Assessing Officer that the sale consideration was the fair market value of the property purchased by him - We delete the addition made by the AO u/s. 56(2)(vii)(b) of the Act. - AT
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