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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Capital gain - determination of cost of acquisition - Inasmuch as the legislative language is clear and unambiguous, we do not find anything perverse in the orders of the authorities below, and merely because of some voluntary act of the mother of the assessee in valuing the property on higher side at the time of receiving of the same, we do not accept the contention that the authorities should have accepted such escalated value. Law contemplates only ‘cost of acquisition’ but not ‘fair market value’. Voluntary acts of the parties will not disturb the legal position or affect the impact of law. - AT
Capital gain - determination of cost of acquisition - Inasmuch as the legislative language is clear and unambiguous, we do not find anything perverse in the orders of the authorities below, and merely because of some voluntary act of the mother of the assessee in valuing the property on higher side at the time of receiving of the same, we do not accept the contention that the authorities should have accepted such escalated value. Law contemplates only ‘cost of acquisition’ but not ‘fair market value’. Voluntary acts of the parties will not disturb the legal position or affect the impact of law. - AT
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