Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
Assessee surrendered allotment of flats, received refund from builder, and claimed long-term capital loss. Held: Assessee acquired 'right to acquire' flats, a capital asset. Surrender of this right constitutes transfer, attracting capital gains computation. Section 50C and 56(2)(X) inapplicable as transfer involved 'right', not land/building. Capital loss carry forward allowed. Penalty under 271(1)(c) not imposable for withdrawing expense claim voluntarily before confrontation by AO, as it would discourage return defect disclosure and violate fairness in tax administration when interest on differential tax paid. Assessee's honesty cannot attract penalties. ITAT allowed assessee's appeal.
Assessee surrendered allotment of flats, received refund from builder, and claimed long-term capital loss. Held: Assessee acquired 'right to acquire' flats, a capital asset. Surrender of this right constitutes transfer, attracting capital gains computation. Section 50C and 56(2)(X) inapplicable as transfer involved 'right', not land/building. Capital loss carry forward allowed. Penalty under 271(1)(c) not imposable for withdrawing expense claim voluntarily before confrontation by AO, as it would discourage return defect disclosure and violate fairness in tax administration when interest on differential tax paid. Assessee's honesty cannot attract penalties. ITAT allowed assessee's appeal.
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