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Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Levy of stamp duty on schemes of amalgamation or restructuring - The High court found that orders of the court sanctioning amalgamation/restructuring, along with the schemes appended to them, are instruments of conveyance under the existing legal framework, thus liable for stamp duty. - The court upheld the circular clarifying the levy of stamp duty on amalgamation schemes but partially invalidated a government order that introduced a new mode of computation for stamp duty based on share value, stating it required legislative action. - The court affirmed the validity of the retrospective application of reduced stamp duty rates, provided by a government order, as beneficial and within the state's power.
Levy of stamp duty on schemes of amalgamation or restructuring - The High court found that orders of the court sanctioning amalgamation/restructuring, along with the schemes appended to them, are instruments of conveyance under the existing legal framework, thus liable for stamp duty. - The court upheld the circular clarifying the levy of stamp duty on amalgamation schemes but partially invalidated a government order that introduced a new mode of computation for stamp duty based on share value, stating it required legislative action. - The court affirmed the validity of the retrospective application of reduced stamp duty rates, provided by a government order, as beneficial and within the state's power.
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