SEZ-unit profit deduction covers voluntary transfer-pricing adjustments, while exempt-income costs, foreign-exchange loss and ITeS comparables are exa...
Infrastructure-development deduction remains available to EPC contractors when substantive statutory conditions outweigh contractor labels in agreemen...
Explained Investment Sources: documented gifts and traceable salary savings supported deletion of additions for property and mutual-fund SIP investmen...
Internal comparable pricing supports arm's-length interest on compulsorily convertible debentures, preventing their recharacterisation as equity for t...
Computation of Capital Gains - Exclusion of the portion of the sale consideration that was never received - The High court found that the real income (capital gains) should be computed based on the actual sale consideration received by the promoters, i.e., after deducting the amounts withdrawn from the escrow account for liabilities. It held that the initial computation, which included the escrow amount not received by the promoters, was incorrect. The full value of consideration for computing capital gains should reflect the actual amount received post-adjustments for liabilities.
Computation of Capital Gains - Exclusion of the portion of the sale consideration that was never received - The High court found that the real income (capital gains) should be computed based on the actual sale consideration received by the promoters, i.e., after deducting the amounts withdrawn from the escrow account for liabilities. It held that the initial computation, which included the escrow amount not received by the promoters, was incorrect. The full value of consideration for computing capital gains should reflect the actual amount received post-adjustments for liabilities.
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