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...
Disallowance of Capital Loss on Sale of Shares - sale of shares due to the amalgamation of certain entities - The AO disallowed the loss, treating it as an artificial loss created on paper. - The ITAT held that the AO unjustifiably disallowed the capital loss. The transactions leading to the loss were legitimate and supported by commercial rationale, including a valid business restructuring and divestment strategy supported by an independent valuation. Therefore, the CIT(A)'s deletion of the disallowance was upheld, dismissing the Revenue's appeal on this issue.
Disallowance of Capital Loss on Sale of Shares - sale of shares due to the amalgamation of certain entities - The AO disallowed the loss, treating it as an artificial loss created on paper. - The ITAT held that the AO unjustifiably disallowed the capital loss. The transactions leading to the loss were legitimate and supported by commercial rationale, including a valid business restructuring and divestment strategy supported by an independent valuation. Therefore, the CIT(A)'s deletion of the disallowance was upheld, dismissing the Revenue's appeal on this issue.
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