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...
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Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
Addition made u/s. 69/69B - difference between the stamp duty value and the sale consideration with respect to purchase of property - family settlement to constitute "transfer" or not - The Tribunal found that the addition under section 69 was incorrect as the investment was recorded in the books. For section 69B, the AO failed to provide evidence that the assessee expended more than recorded. The Tribunal also noted that section 56(2)(vii)(b) was not applicable to companies and section 56(2)(x) was effective from AY 2017-18. The Tribunal concluded that the transaction under family settlement did not amount to a "transfer" and deleted the addition.
Addition made u/s. 69/69B - difference between the stamp duty value and the sale consideration with respect to purchase of property - family settlement to constitute "transfer" or not - The Tribunal found that the addition under section 69 was incorrect as the investment was recorded in the books. For section 69B, the AO failed to provide evidence that the assessee expended more than recorded. The Tribunal also noted that section 56(2)(vii)(b) was not applicable to companies and section 56(2)(x) was effective from AY 2017-18. The Tribunal concluded that the transaction under family settlement did not amount to a "transfer" and deleted the addition.
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