Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
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In an ITAT decision on section 50C, the Tribunal held that where agricultural land was sold under a single arrangement and the entire consideration was received by cheque at the time of the agreement to sell, the stamp duty value on the later registration dates could not be treated as the full value of consideration. It accepted the assessee's evidence of the December 2007 agreement and related valuation material, and treated the curative amendment to section 50C as retrospective. The relevant stamp valuation was therefore the value prevailing on the agreement date, and the addition made under section 50C was deleted.
In an ITAT decision on section 50C, the Tribunal held that where agricultural land was sold under a single arrangement and the entire consideration was received by cheque at the time of the agreement to sell, the stamp duty value on the later registration dates could not be treated as the full value of consideration. It accepted the assessee's evidence of the December 2007 agreement and related valuation material, and treated the curative amendment to section 50C as retrospective. The relevant stamp valuation was therefore the value prevailing on the agreement date, and the addition made under section 50C was deleted.
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