Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Capital gains exemption u/s 54F denied due to non-completion of construction within the stipulated period. The assessee entered into a Joint Development Agreement (JDA), receiving a residential villa in exchange for a plot of land. Despite a delay of over 7 years in completing construction against the 3-year period u/s 54F, the assessee failed to substantiate the explanation of a dispute among partners. No evidence was provided to demonstrate efforts made by the assessee to enforce rights under the agreement or ensure timely completion. Lack of vigilance and failure to exercise due diligence resulted in the dismissal of appeals by the Appellate Tribunal.
Capital gains exemption u/s 54F denied due to non-completion of construction within the stipulated period. The assessee entered into a Joint Development Agreement (JDA), receiving a residential villa in exchange for a plot of land. Despite a delay of over 7 years in completing construction against the 3-year period u/s 54F, the assessee failed to substantiate the explanation of a dispute among partners. No evidence was provided to demonstrate efforts made by the assessee to enforce rights under the agreement or ensure timely completion. Lack of vigilance and failure to exercise due diligence resulted in the dismissal of appeals by the Appellate Tribunal.
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