Marketing support and subcontracted client contracts: no agency permanent establishment under Article 5 DTAA; arm's-length pricing bars profit attribu...
Transfer pricing comparables selection and working capital adjustment u/r 10B(1)(e)(iii), remanded for recomputation with rejected comparables include...
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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