Restricted silver imports may clear under a valid import authorisation without additional status or exchange-routing requirements unless expressly imp...
Head Office cost allocation requires prescribed transfer-pricing methods; treaty ceilings bar surcharge and cess, while duplicate taxation is excluded...
Cost-to-cost reimbursement of seconded employees is not service consideration; transfer-pricing markup was deleted and amalgamation amortisation allow...
Crystallisation of liability supports prior-period expense deduction, while functionally distinct divisions require separate transfer-pricing benchmar...
Section 50C does not extend to relinquishment of an unregistered contractual right to seek specific performance of an agreement to sell land. Where no sale deed is registered in the transferee's favour and the vendor remains owner, the relinquished right is a capital asset comprising a contractual remedy, not land or building. The deeming fiction is confined to transfers of land or building and cannot be enlarged to cover such rights. A registered leasehold interest was distinguished because it confers possessory and enjoyment rights in rem. The recomputation of long-term capital gain under section 50C and the resulting addition were deleted.
Section 50C does not extend to relinquishment of an unregistered contractual right to seek specific performance of an agreement to sell land. Where no sale deed is registered in the transferee's favour and the vendor remains owner, the relinquished right is a capital asset comprising a contractual remedy, not land or building. The deeming fiction is confined to transfers of land or building and cannot be enlarged to cover such rights. A registered leasehold interest was distinguished because it confers possessory and enjoyment rights in rem. The recomputation of long-term capital gain under section 50C and the resulting addition were deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4905 
