Reopening of assessment cannot rest solely on an audit party's opinion; reassessment under Section 147/148 is impermissible and power of revision shou...
Tested party selection: functional analysis identified the least complex unit as the appropriate tested party, altering the transfer pricing adjustmen...
For computing LTCG under the deeming fiction of s.50C, the relevant SRO value is the value prevailing on the date of the operative "agreement to sell"/settlement document, provided the statutory preconditions are satisfied; accordingly, SRO value as on 23.11.2013 was directed for the land covered by the court-recorded compromise, and SRO value as on 12.08.2013 was directed for the land covered by the MOUs. For the balance land not traceable to the compromise/MOUs, SRO value as on the dates of the last registered sale deeds in November 2015 was directed. The appellate order was set aside and recomputation was ordered on these lines - ITAT
For computing LTCG under the deeming fiction of s.50C, the relevant SRO value is the value prevailing on the date of the operative "agreement to sell"/settlement document, provided the statutory preconditions are satisfied; accordingly, SRO value as on 23.11.2013 was directed for the land covered by the court-recorded compromise, and SRO value as on 12.08.2013 was directed for the land covered by the MOUs. For the balance land not traceable to the compromise/MOUs, SRO value as on the dates of the last registered sale deeds in November 2015 was directed. The appellate order was set aside and recomputation was ordered on these lines - ITAT
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