Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
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The Delhi High Court held that interest received on the principal amount deposited by the assessee following an auction sale cancellation is a capital receipt and not taxable. The amount was not compensation but a refund of the successful bidder's deposit. The interest is not revenue and falls outside the scope of Section 56(2)(viii) of the Act. The ITAT's decision was upheld, confirming the interest as a capital receipt exempt from tax.
The Delhi High Court held that interest received on the principal amount deposited by the assessee following an auction sale cancellation is a capital receipt and not taxable. The amount was not compensation but a refund of the successful bidder's deposit. The interest is not revenue and falls outside the scope of Section 56(2)(viii) of the Act. The ITAT's decision was upheld, confirming the interest as a capital receipt exempt from tax.
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