Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Addition u/s 56(2)(vii)(b) - Purchase of property below circle rate / stamp value - since the assessee/co-owners has made part payment (part consideration of Rs. 3 Lakhs) by cheque , therefore, the date of agreement as per the proviso to section 56(2)(vii) (b) of the Act should be taken as 25.11.2011. In such a scenario, the stamp duty value as on the date of agreement must be taken for the purpose of taxation under consideration u/s 56(2)(vii)(b). - AT
Addition u/s 56(2)(vii)(b) - Purchase of property below circle rate / stamp value - since the assessee/co-owners has made part payment (part consideration of Rs. 3 Lakhs) by cheque , therefore, the date of agreement as per the proviso to section 56(2)(vii) (b) of the Act should be taken as 25.11.2011. In such a scenario, the stamp duty value as on the date of agreement must be taken for the purpose of taxation under consideration u/s 56(2)(vii)(b). - AT
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