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Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Capital gains for AY 2016-17 had to be recomputed by correcting an assessment-year mismatch, excluding a property transfer recorded in the succeeding year and including the deed relating to the year under consideration. The Tribunal also treated one sale entry as a duplicate because the later document merely rectified an error in the earlier deed, so only the corrected transaction could be counted. For the co-owned property sale, where the deed did not specify separate shares, the assessee's taxable share was restricted to one-fifth of the total consideration. The assessment was revised accordingly.
Capital gains for AY 2016-17 had to be recomputed by correcting an assessment-year mismatch, excluding a property transfer recorded in the succeeding year and including the deed relating to the year under consideration. The Tribunal also treated one sale entry as a duplicate because the later document merely rectified an error in the earlier deed, so only the corrected transaction could be counted. For the co-owned property sale, where the deed did not specify separate shares, the assessee's taxable share was restricted to one-fifth of the total consideration. The assessment was revised accordingly.
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