Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
FEMA borrowing restrictions bind charitable trusts, and civil penalties apply without proving intent for delayed repayment of non-resident rupee loans...
The Appellate Tribunal addressed the issue of the retrospective or prospective application of amended provisions of Section 50C regarding Capital Gain computation. Citing a case precedent, it was held that the proviso to Section 50C(1) should be considered retrospective from its inception. Consequently, the amendment to Section 50C applies retrospectively, requiring the recomputation of capital gains based on stamp duty value at the agreement date. The decision favored the taxpayer, rejecting the revenue's stance.
The Appellate Tribunal addressed the issue of the retrospective or prospective application of amended provisions of Section 50C regarding Capital Gain computation. Citing a case precedent, it was held that the proviso to Section 50C(1) should be considered retrospective from its inception. Consequently, the amendment to Section 50C applies retrospectively, requiring the recomputation of capital gains based on stamp duty value at the agreement date. The decision favored the taxpayer, rejecting the revenue's stance.
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