Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
Fake AI-generated precedents vitiate adjudication, with unverified citations contaminating the decision-making process and undermining the rule of law...
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should be computed based on the actual sale consideration received by the promoters, i.e., after deducting the amounts withdrawn from the escrow account for liabilities.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should be computed based on the actual sale consideration received by the promoters, i.e., after deducting the amounts withdrawn from the escrow account for liabilities.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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