Clubbing of income from gifted property failed where the claim surfaced after reassessment limitation, sustaining capital-gains assessment in spouse's...
Employee stock-option discount qualifies as revenue expenditure, while royalty and service comparables require reliable functional and transactional b...
Special insurance income computation preserves statutory deductions while limiting transfer-pricing, withholding and disallowance adjustments for gene...
The safe-harbour tolerance-band proviso to section 56(2)(x)(b) addresses unintended hardship where purchase consideration and stamp-duty value differ only marginally. Its remedial and clarificatory character supports application from the provision's original operation, including Assessment Year 2018-19, rather than only prospectively. As the proviso is pari materia with related stamp-duty valuation provisions, a variation within the statutory tolerance margin does not sustain a deeming addition. The marginal valuation difference therefore did not justify addition as deemed income.
The safe-harbour tolerance-band proviso to section 56(2)(x)(b) addresses unintended hardship where purchase consideration and stamp-duty value differ only marginally. Its remedial and clarificatory character supports application from the provision's original operation, including Assessment Year 2018-19, rather than only prospectively. As the proviso is pari materia with related stamp-duty valuation provisions, a variation within the statutory tolerance margin does not sustain a deeming addition. The marginal valuation difference therefore did not justify addition as deemed income.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4913 
