Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
The Appellate Tribunal considered the applicability of u/s 50C regarding capital gain computation for the transfer of leasehold rights. It was held that u/s 50C applies only to land or building, not lease rights. Citing precedents, it was noted that u/s 50C does not cover leasehold rights. The deeming provision of u/s 50C substitutes stamp valuation authority's value if lower than consideration received. As leasehold rights are not covered, u/s 50C does not apply. The AO can compute capital gains without invoking u/s 50C.
The Appellate Tribunal considered the applicability of u/s 50C regarding capital gain computation for the transfer of leasehold rights. It was held that u/s 50C applies only to land or building, not lease rights. Citing precedents, it was noted that u/s 50C does not cover leasehold rights. The deeming provision of u/s 50C substitutes stamp valuation authority's value if lower than consideration received. As leasehold rights are not covered, u/s 50C does not apply. The AO can compute capital gains without invoking u/s 50C.
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