Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Capital gain - Denial of benefit of 1st proviso to section 50C(1) which allows the consideration value fixed in the agreement to be considered instead of the stamp valuation for the computation of full value of consideration for transfer. - Proof of agreement prior to application of section 50C - The Tribunal noted that a part of the consideration must be received through specific banking channels before the agreement date. As the payment did not meet this requirement, the benefit of the first proviso was denied. - The ITAT also dismissed the contention regarding the denial of deduction under section 54B, upholding the lower authorities' decision.
Capital gain - Denial of benefit of 1st proviso to section 50C(1) which allows the consideration value fixed in the agreement to be considered instead of the stamp valuation for the computation of full value of consideration for transfer. - Proof of agreement prior to application of section 50C - The Tribunal noted that a part of the consideration must be received through specific banking channels before the agreement date. As the payment did not meet this requirement, the benefit of the first proviso was denied. - The ITAT also dismissed the contention regarding the denial of deduction under section 54B, upholding the lower authorities' decision.
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