Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
Addition u/s. 56(2)(viib) - transaction of sale of agricultural land - consideration as per the stamp value - The Tribunal admitted additional evidence provided by the appellant, consisting of certificates from Municipal Authorities and Gram Panchayat, supporting the agricultural nature of the land. After considering the evidence and legal arguments, the Tribunal concluded that the land in question did not qualify as a capital asset u/s 2(14). Since the agricultural land was not categorized as a capital asset, the provisions of section 56(2)(viib) were deemed inapplicable. Consequently, the addition made by the AO under section 56(2)(viib) was deleted.
Addition u/s. 56(2)(viib) - transaction of sale of agricultural land - consideration as per the stamp value - The Tribunal admitted additional evidence provided by the appellant, consisting of certificates from Municipal Authorities and Gram Panchayat, supporting the agricultural nature of the land. After considering the evidence and legal arguments, the Tribunal concluded that the land in question did not qualify as a capital asset u/s 2(14). Since the agricultural land was not categorized as a capital asset, the provisions of section 56(2)(viib) were deemed inapplicable. Consequently, the addition made by the AO under section 56(2)(viib) was deleted.
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