Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...
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Short Term Capital Gain - conversion of the Partnership Firms into Companies - Additions in the hands of partners - CIT (Appeals) correctly deleted the additions on account of capital gain made in the hands of the Partners as he was of the opinion that the applicability of section 47(xiii)(b) at the time of conversion of the Partnership Firms into Companies can be considered only in the hands of the Partnership Firms to which the land belongs. - AT
Short Term Capital Gain - conversion of the Partnership Firms into Companies - Additions in the hands of partners - CIT (Appeals) correctly deleted the additions on account of capital gain made in the hands of the Partners as he was of the opinion that the applicability of section 47(xiii)(b) at the time of conversion of the Partnership Firms into Companies can be considered only in the hands of the Partnership Firms to which the land belongs. - AT
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