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 High Court held that the amendment introducing the words "or assessable" in Section 50C of the Income Tax Act, effective from October 1, 2009, cannot be applied retrospectively. Prior to the amendment, Section 50C was applicable only to transfers where the value was adopted or assessed by the stamp valuation authority. The inclusion of the phrase "or assessable" brought transfers where the value is assessable by the stamp valuation authority within the ambit of Section 50C. This introduction of a new class of transactions can only have prospective application and cannot be applied to transfers made before the amendment. Consequently, the assessee's transfer, which occurred before the amendment, cannot be subjected to Section 50C. The decision was in favor of the assessee.
The High Court held that the amendment introducing the words "or assessable" in Section 50C of the Income Tax Act, effective from October 1, 2009, cannot be applied retrospectively. Prior to the amendment, Section 50C was applicable only to transfers where the value was adopted or assessed by the stamp valuation authority. The inclusion of the phrase "or assessable" brought transfers where the value is assessable by the stamp valuation authority within the ambit of Section 50C. This introduction of a new class of transactions can only have prospective application and cannot be applied to transfers made before the amendment. Consequently, the assessee's transfer, which occurred before the amendment, cannot be subjected to Section 50C. The decision was in favor of the assessee.
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