Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
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Addition u/s 50C r.w.s. 56(2)(vii) (b) - the buyer of the property - The Tribunal (ITAT) ruled that since the assesses were buyers, Section 50C did not apply, and Section 56(2)(vii)(b) did not apply as the property was not acquired without consideration. The retrospective application of Section 56(2)(vii)(b) was also rejected. Additionally, the Tribunal found no grounds for addition under Section 69C, as no show cause notice was issued and the initial addition was not sustained. Consequently, the appeals by both assesses were allowed. Additionally, the Tribunal found no grounds for addition under Section 69C, as no show cause notice was issued and the initial addition was not sustained.
Addition u/s 50C r.w.s. 56(2)(vii) (b) - the buyer of the property - The Tribunal (ITAT) ruled that since the assesses were buyers, Section 50C did not apply, and Section 56(2)(vii)(b) did not apply as the property was not acquired without consideration. The retrospective application of Section 56(2)(vii)(b) was also rejected. Additionally, the Tribunal found no grounds for addition under Section 69C, as no show cause notice was issued and the initial addition was not sustained. Consequently, the appeals by both assesses were allowed. Additionally, the Tribunal found no grounds for addition under Section 69C, as no show cause notice was issued and the initial addition was not sustained.
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