Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
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In the case before ITAT Jabalpur, the issue revolved around the addition u/s 43CA concerning the variance between the sale consideration and the market value of a property. The AO contended that an unregistered agreement of sale could not be legally recognized and highlighted discrepancies in parties involved in transactions. However, the Tribunal ruled in favor of the assessee, recognizing entitlement to benefits u/s 43CA (3) for plots booked in specific financial years. The AO was directed to recalculate profits, considering detailed registry information on plot sales annually and granting the benefits of Section 43CA accordingly.
In the case before ITAT Jabalpur, the issue revolved around the addition u/s 43CA concerning the variance between the sale consideration and the market value of a property. The AO contended that an unregistered agreement of sale could not be legally recognized and highlighted discrepancies in parties involved in transactions. However, the Tribunal ruled in favor of the assessee, recognizing entitlement to benefits u/s 43CA (3) for plots booked in specific financial years. The AO was directed to recalculate profits, considering detailed registry information on plot sales annually and granting the benefits of Section 43CA accordingly.
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