Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
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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