Business deductions and transfer pricing issues: tribunal treatment of software write-offs, donation receipts, warranty provisions, and related expens...
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The ITAT Ahmedabad ruled on two key issues: 1) Determination of Selling Price of Shares for LTCG Calculation - Held that the AR's contention regarding higher consideration for shareholders who were tenants is justifiable. Section 50C not applicable to share of Private Limited Company. Decision of CIT vs. Salora International Limited not applicable due to distinguishing facts. 2) Deduction of rent paid against HRA - Assessee provided evidence of paying rent to HUF. Allowed deduction based on Tribunal decisions. Grounds 1 and 2 allowed.
The ITAT Ahmedabad ruled on two key issues: 1) Determination of Selling Price of Shares for LTCG Calculation - Held that the AR's contention regarding higher consideration for shareholders who were tenants is justifiable. Section 50C not applicable to share of Private Limited Company. Decision of CIT vs. Salora International Limited not applicable due to distinguishing facts. 2) Deduction of rent paid against HRA - Assessee provided evidence of paying rent to HUF. Allowed deduction based on Tribunal decisions. Grounds 1 and 2 allowed.
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