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 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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