Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Addition invoking provisions u/s 56(2)(vii)(b) - assessee only received lease hold right for 99 years - difference of stamp value minus sales consideration - The definition of property does not refer to rights or transactions which may enable use or enjoyment of property and it appears that having regards to description context and objective, acquisition of such rights cannot be equated with immovable property. - AT
Addition invoking provisions u/s 56(2)(vii)(b) - assessee only received lease hold right for 99 years - difference of stamp value minus sales consideration - The definition of property does not refer to rights or transactions which may enable use or enjoyment of property and it appears that having regards to description context and objective, acquisition of such rights cannot be equated with immovable property. - AT
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