Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
Issue concerns eligibility for capital gains exemption under Section 54 where the replacement dwelling was an under construction flat. The article explains the Tribunal treated acquisition as effected on discharge of balance consideration and taking possession on completion, not on execution of the booking agreement. Applying the substance of the transaction, possession/payment on completion (07-01-2015) was held to be the relevant date for the two year compliance measured from transfer (28-10-2013), therefore the statutory conditions were satisfied and the exemption was allowed.
Issue concerns eligibility for capital gains exemption under Section 54 where the replacement dwelling was an under construction flat. The article explains the Tribunal treated acquisition as effected on discharge of balance consideration and taking possession on completion, not on execution of the booking agreement. Applying the substance of the transaction, possession/payment on completion (07-01-2015) was held to be the relevant date for the two year compliance measured from transfer (28-10-2013), therefore the statutory conditions were satisfied and the exemption was allowed.
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