Functional, asset and risk analysis excludes diversified technology companies from captive software development comparables under cost-plus arrangemen...
Mobile-phone electronic evidence failed to establish customs undervaluation, while duty survived on non-authentic origin certificates without importer...
Automotive radio classification treats integrated infotainment features as supplementary, placing complete and qualifying unassembled units under the ...
Separate corporate personality prevents directors from being personally liable for company deposits without a guarantee or independent legal undertaki...
Cross-segment derivatives manipulation: integrated order patterns can support interim restraints, while director liability requires responsibility, co...
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 4907 
