Concessional corporate tax option under section 115BAA survives procedural documentary lapses when statutory compliance and earlier exercise are estab...
Penny-stock additions require transaction-specific evidence; general investigation material alone cannot establish undisclosed income or accommodation...
Transfer pricing comparability prioritises reliable external CUPs and foreign-currency LIBOR benchmarks for exports, borrowings and delayed receivable...
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Section 50C applies only to transfers of capital assets and not to sale of stock-in-trade assessed as business income. Where real estate plots are claimed to form business inventory, the decisive question is whether the assessee was carrying on a real estate business and held the lands as stock-in-trade; the Tribunal remitted that limited factual issue to the Assessing Officer for fresh examination and directed deletion of the addition if the claim is proved. The connected penalty matters under sections 271D and 271(1)(c) were also restored for fresh adjudication because they depended on the remanded quantum issue.
Section 50C applies only to transfers of capital assets and not to sale of stock-in-trade assessed as business income. Where real estate plots are claimed to form business inventory, the decisive question is whether the assessee was carrying on a real estate business and held the lands as stock-in-trade; the Tribunal remitted that limited factual issue to the Assessing Officer for fresh examination and directed deletion of the addition if the claim is proved. The connected penalty matters under sections 271D and 271(1)(c) were also restored for fresh adjudication because they depended on the remanded quantum issue.
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