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...
Redevelopment hardship compensation received as a predetermined lump-sum for shifting, re-shifting, demolition-related inconvenience and shared common areas was held to be a capital receipt, not consideration for transfer of property rights, so the addition was deleted. The first appellate authority's direction to compute capital gain on the additional 56% carpet area was treated as an enhancement of income; because no prior show-cause notice or opportunity under section 251(2) was shown, that enhancement was set aside and the issue was remitted for fresh consideration after hearing the assessee.
Redevelopment hardship compensation received as a predetermined lump-sum for shifting, re-shifting, demolition-related inconvenience and shared common areas was held to be a capital receipt, not consideration for transfer of property rights, so the addition was deleted. The first appellate authority's direction to compute capital gain on the additional 56% carpet area was treated as an enhancement of income; because no prior show-cause notice or opportunity under section 251(2) was shown, that enhancement was set aside and the issue was remitted for fresh consideration after hearing the assessee.
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