Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
Fake AI-generated precedents vitiate adjudication, with unverified citations contaminating the decision-making process and undermining the rule of law...
Capital gain - Taxability in the hands of GPA holder - the sale deed executed by the assessee on 04.01.2011 is not in the capacity of GPA holder on behalf of the original owners. There is no recital in the sale deed executed by the assessee on 04.01.2011 that the sale consideration was received by the assessee on behalf of the original owners. He has also not placed any evidence to establish that he has repaid the amount to the original owners. Therefore, the capital gains arising out of the transfer occurred on 04.01.2011 should be charged in the hands of the assessee only. - AT
Capital gain - Taxability in the hands of GPA holder - the sale deed executed by the assessee on 04.01.2011 is not in the capacity of GPA holder on behalf of the original owners. There is no recital in the sale deed executed by the assessee on 04.01.2011 that the sale consideration was received by the assessee on behalf of the original owners. He has also not placed any evidence to establish that he has repaid the amount to the original owners. Therefore, the capital gains arising out of the transfer occurred on 04.01.2011 should be charged in the hands of the assessee only. - AT
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