Form 26AS evidence requires successor-entity accounting verification after business transfer, while invoice-supported related-party advertising expend...
Money-laundering judgment timing requires awaiting the scheduled-offence decision despite continuation of the underlying trial where outcomes directly...
Accredited investor eligibility expands through securities-market exposure, while alternative investment fund disputes require prescribed resolution a...
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Transfer Pricing Adjustments - Purchase of Development Rights - capital transactions and their treatment - The tribunal addressed several crucial issues regarding the purchase of development rights, including the applicability of transfer pricing provisions to transactions capitalized in the books of accounts and not directly affecting the profit and loss account. One of the most contentious issues was the use of circle rates for determining the arm's length price of the transaction. Circle rates, usually used for stamp duty purposes, were considered by the TPO as a benchmark for the arm's length price. - The tribunal concludes that the omission of clause (i) of section 92BA of the Income Tax Act, 1961, should be treated as if the clause had never been part of the statute, thereby precluding transfer pricing adjustments on specified domestic transactions from the date of omission.
Transfer Pricing Adjustments - Purchase of Development Rights - capital transactions and their treatment - The tribunal addressed several crucial issues regarding the purchase of development rights, including the applicability of transfer pricing provisions to transactions capitalized in the books of accounts and not directly affecting the profit and loss account. One of the most contentious issues was the use of circle rates for determining the arm's length price of the transaction. Circle rates, usually used for stamp duty purposes, were considered by the TPO as a benchmark for the arm's length price. - The tribunal concludes that the omission of clause (i) of section 92BA of the Income Tax Act, 1961, should be treated as if the clause had never been part of the statute, thereby precluding transfer pricing adjustments on specified domestic transactions from the date of omission.
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