Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...
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HC remanded tax assessment proceedings involving long-term capital gains on property sale. The ITAT directed de novo assessment requiring personal hearing, which the assessing officer failed to provide. The court found the officer improperly considered previous materials and did not grant the assessee an opportunity to be heard through video conference. Regarding Section 50-C, the court clarified that guideline value supersedes sale deed value for tax calculation, and the petitioner is entitled to be heard on tax liability proportionate to property ownership. The matter was consequently returned to the assessing officer for proper procedural compliance, with the writ appeal being allowed.
HC remanded tax assessment proceedings involving long-term capital gains on property sale. The ITAT directed de novo assessment requiring personal hearing, which the assessing officer failed to provide. The court found the officer improperly considered previous materials and did not grant the assessee an opportunity to be heard through video conference. Regarding Section 50-C, the court clarified that guideline value supersedes sale deed value for tax calculation, and the petitioner is entitled to be heard on tax liability proportionate to property ownership. The matter was consequently returned to the assessing officer for proper procedural compliance, with the writ appeal being allowed.
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