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...
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The ITAT allowed the assessee's appeal against the PCIT's revision order under s. 263 directing addition under s. 56(2)(vii)(b) for difference between stamp duty value and actual sale consideration of land. The Tribunal held that s. 56(2)(vii)(b) applies only to individuals/HUFs who "received" capital assets at lower prices, but here the partnership firm M/s Goyal Sons was the actual purchaser, not the individual assessees who were merely partners. The ITAT noted that s. 56(2)(x), which extends to "any person" including partnership firms, was introduced prospectively from 01.04.2017 and not applicable to AY 2016-17. The assessment order was neither erroneous nor prejudicial to Revenue's interests, thus failing to satisfy conditions precedent for s. 263 revision.
The ITAT allowed the assessee's appeal against the PCIT's revision order under s. 263 directing addition under s. 56(2)(vii)(b) for difference between stamp duty value and actual sale consideration of land. The Tribunal held that s. 56(2)(vii)(b) applies only to individuals/HUFs who "received" capital assets at lower prices, but here the partnership firm M/s Goyal Sons was the actual purchaser, not the individual assessees who were merely partners. The ITAT noted that s. 56(2)(x), which extends to "any person" including partnership firms, was introduced prospectively from 01.04.2017 and not applicable to AY 2016-17. The assessment order was neither erroneous nor prejudicial to Revenue's interests, thus failing to satisfy conditions precedent for s. 263 revision.
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