Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
ITAT held that the assessee's property transaction did not constitute a short-term capital gain. The tribunal found no evidence of actual property transfer or possession, and the total consideration paid (Rs. 5,00,20,000) exceeded the market valuation (Rs. 4,74,00,000). The unregistered agreement was not considered a valid sale deed. The appellate tribunal set aside the lower authorities' order, directing the AO to delete additions under section 56(vii)(b), effectively allowing the assessee's appeal and rejecting revenue's claims of undervaluation.
ITAT held that the assessee's property transaction did not constitute a short-term capital gain. The tribunal found no evidence of actual property transfer or possession, and the total consideration paid (Rs. 5,00,20,000) exceeded the market valuation (Rs. 4,74,00,000). The unregistered agreement was not considered a valid sale deed. The appellate tribunal set aside the lower authorities' order, directing the AO to delete additions under section 56(vii)(b), effectively allowing the assessee's appeal and rejecting revenue's claims of undervaluation.
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