Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
Capital Gain - Transfer of property u/s 2(47) - Scope of Consent Terms (Agreement) - Nothing has been brought on record by the AO to show that the Purchaser was willing to perform his part of contract. The Consent Terms were agreed upon only after the Appellant filed suit for seeking specific performance of the Agreement for Sale. Therefore, we hold that the transaction under consideration did not attract provisions of Section 53A of the TPA. - AT
Capital Gain - Transfer of property u/s 2(47) - Scope of Consent Terms (Agreement) - Nothing has been brought on record by the AO to show that the Purchaser was willing to perform his part of contract. The Consent Terms were agreed upon only after the Appellant filed suit for seeking specific performance of the Agreement for Sale. Therefore, we hold that the transaction under consideration did not attract provisions of Section 53A of the TPA. - AT
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