Minimum alternate tax exclusions for pre-amendment banking companies and expatriate Indian branch salaries remain outside head office expenditure limi...
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Addition u/s 56(2)(vii)(b) - transfer under gift deed - family settlement- The Assessee contended that the transfer of land through a gift deed was part of a family settlement/arrangement between the parties involved. They argued that various documents, including a family settlement arrangement and MOUs, supported their position. The Revenue, however, maintained that the transfer was without consideration and fell within the ambit of deemed income under the Act. - The ITAT concluded that the transaction should be understood in the context of the broader arrangement and not in isolation. Therefore, the addition made by the AO was deemed unjustified, and the appeal of the Assessee was allowed.
Addition u/s 56(2)(vii)(b) - transfer under gift deed - family settlement- The Assessee contended that the transfer of land through a gift deed was part of a family settlement/arrangement between the parties involved. They argued that various documents, including a family settlement arrangement and MOUs, supported their position. The Revenue, however, maintained that the transfer was without consideration and fell within the ambit of deemed income under the Act. - The ITAT concluded that the transaction should be understood in the context of the broader arrangement and not in isolation. Therefore, the addition made by the AO was deemed unjustified, and the appeal of the Assessee was allowed.
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