Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...
Where a registered sale deed was subsequently cancelled by a registered cancellation deed and the purchaser's share of the sale consideration was repaid as recorded in the cancellation deed, there was no subsisting transfer or benefit taxable as imputed income under the gifts/imputed-income provision; the cancellation with repayment removed the legal basis for treating the difference between stamp valuation and declared consideration as income, and the addition made on that ground was deleted with the appeal allowed.
Where a registered sale deed was subsequently cancelled by a registered cancellation deed and the purchaser's share of the sale consideration was repaid as recorded in the cancellation deed, there was no subsisting transfer or benefit taxable as imputed income under the gifts/imputed-income provision; the cancellation with repayment removed the legal basis for treating the difference between stamp valuation and declared consideration as income, and the addition made on that ground was deleted with the appeal allowed.
Note: It is a system-generated summary and is for quick reference only.
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