Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
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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