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...
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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