Transfer pricing adjustments for software services, corporate guarantees, expense characterisation and foreign tax credit affirmed under arm's length ...
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ITAT held that no "transfer" of capital asset occurred in AY 2015-16 under the sale agreements for three office properties, as only 5-13% of the agreed consideration was received and contractual conditions for transfer, including full payment and handing over of documents/possession, were not fulfilled. Buyers' confirmations corroborated non-payment of full consideration and non-delivery of possession. The Tribunal further accepted that capital gains were correctly offered and assessed in AY 2018-19 when full consideration was received, and the Revenue could not tax the same transaction twice. Accordingly, the addition for capital gains in AY 2015-16 was deleted and the assessee's appeal was allowed.
ITAT held that no "transfer" of capital asset occurred in AY 2015-16 under the sale agreements for three office properties, as only 5-13% of the agreed consideration was received and contractual conditions for transfer, including full payment and handing over of documents/possession, were not fulfilled. Buyers' confirmations corroborated non-payment of full consideration and non-delivery of possession. The Tribunal further accepted that capital gains were correctly offered and assessed in AY 2018-19 when full consideration was received, and the Revenue could not tax the same transaction twice. Accordingly, the addition for capital gains in AY 2015-16 was deleted and the assessee's appeal was allowed.
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