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 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.
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