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 assessee undervalued sales in books compared to market value of flats. Received advances per agreement, executed sale deeds later at agreement value. No addition under sec 43CA as part consideration received by cheque based on agreement. ITAT directed AO to delete addition. Excess payment to purchaser not interest, no TDS obligation per Beacon Projects case. Amount paid for surrender of rights not interest, no TDS obligation. Sec 40(a)(ia) not applicable. Decided in favor of assessee.
The assessee undervalued sales in books compared to market value of flats. Received advances per agreement, executed sale deeds later at agreement value. No addition under sec 43CA as part consideration received by cheque based on agreement. ITAT directed AO to delete addition. Excess payment to purchaser not interest, no TDS obligation per Beacon Projects case. Amount paid for surrender of rights not interest, no TDS obligation. Sec 40(a)(ia) not applicable. Decided in favor of assessee.
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