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...
Where a capital asset devolved on the assessee by succession or trust devolution, the period for which the asset was held by the previous owner/trust is to be included in computing holding period, making the asset a long-term capital asset. The Tribunal upheld allowance of exemption for investment in specified bonds, finding no material contradicting compliance with the bond-investment timing. Claim under the residential-house reinvestment exemption required actual purchase evidence; only an agreement was produced, so the matter was remanded to the Assessing Officer to verify execution of a registered conveyance/purchase deed within the statutory period and decide after hearing the assessee.
Where a capital asset devolved on the assessee by succession or trust devolution, the period for which the asset was held by the previous owner/trust is to be included in computing holding period, making the asset a long-term capital asset. The Tribunal upheld allowance of exemption for investment in specified bonds, finding no material contradicting compliance with the bond-investment timing. Claim under the residential-house reinvestment exemption required actual purchase evidence; only an agreement was produced, so the matter was remanded to the Assessing Officer to verify execution of a registered conveyance/purchase deed within the statutory period and decide after hearing the assessee.
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