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...
The petitioner's transaction of sale of immovable property was complete in the assessment year (AY) 2005-06 through execution of agreement, receipt of consideration, and handing over possession, though the sale deed was registered in July 2008. As per Section 47 of the Registration Act, 1908, the sale deed relates back to AY 2005-06, not the date of registration. In AY 2006-07, neither sale nor registration occurred, precluding reassessment proceedings u/s 148 to determine capital gains. Consequently, the impugned order and notices were quashed by the High Court, holding that the correct assessment year was AY 2005-06 when the transaction was disclosed in the income tax returns.
The petitioner's transaction of sale of immovable property was complete in the assessment year (AY) 2005-06 through execution of agreement, receipt of consideration, and handing over possession, though the sale deed was registered in July 2008. As per Section 47 of the Registration Act, 1908, the sale deed relates back to AY 2005-06, not the date of registration. In AY 2006-07, neither sale nor registration occurred, precluding reassessment proceedings u/s 148 to determine capital gains. Consequently, the impugned order and notices were quashed by the High Court, holding that the correct assessment year was AY 2005-06 when the transaction was disclosed in the income tax returns.
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