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...
Receipt of a new residential flat in exchange for surrender of an old flat under a redevelopment arrangement was held not to be receipt of immovable property for inadequate consideration within section 56(2)(x). The Tribunal, relying on its earlier decision in Anil Dattaram Pitale v. ITO, found that the transaction was an exchange linked to redevelopment rather than a taxable transfer attracting deemed income. The addition made under section 56(2)(x) was therefore deleted in full, and the appeal was allowed on merits.
Receipt of a new residential flat in exchange for surrender of an old flat under a redevelopment arrangement was held not to be receipt of immovable property for inadequate consideration within section 56(2)(x). The Tribunal, relying on its earlier decision in Anil Dattaram Pitale v. ITO, found that the transaction was an exchange linked to redevelopment rather than a taxable transfer attracting deemed income. The addition made under section 56(2)(x) was therefore deleted in full, and the appeal was allowed on merits.
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