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...
Section 43CA applies only to transfer of land or building or both held as stock-in-trade, and its deeming fiction cannot be extended to TDR/FSI rights. Because transferable development rights are intangible development rights and not land or building per se, adoption of stamp duty value for their transfer was held impermissible. The addition made under section 43CA was therefore deleted, and the Revenue's appeal failed.
Section 43CA applies only to transfer of land or building or both held as stock-in-trade, and its deeming fiction cannot be extended to TDR/FSI rights. Because transferable development rights are intangible development rights and not land or building per se, adoption of stamp duty value for their transfer was held impermissible. The addition made under section 43CA was therefore deleted, and the Revenue's appeal failed.
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