https://www.taxtmi.com/caselaws?id=401717 A share transfer without consideration was not accepted as a valid gift because the surrounding restructuring, board resolution and contemporaneous conduct showed it was not a genuinely voluntary and gratuitous transfer with the required acceptance; the exemption for gifts therefore did not apply and capital gains tax was attracted. The transfer pricing additions on trademark licence fee and corporate and bank guarantees were upheld because the assessee did not establish ownership of the mark and intra-group guarantees were treated as international transactions capable of arm's length adjustment. The 10% risk adjustment linked to the private equity investment was rejected as unsupported by the factual record and the investment price was treated as the best market indicator. en-us Thu, 10 Dec 2020 00:00:00 +0530 Mon, 15 Sep 2025 12:59:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=401717 A share transfer without consideration was not accepted as a valid gift because the surrounding restructuring, board resolution and contemporaneous conduct showed it was not a genuinely voluntary and gratuitous transfer with the required acceptance; the exemption for gifts therefore did not apply and capital gains tax was attracted. The transfer pricing additions on trademark licence fee and corporate and bank guarantees were upheld because the assessee did not establish ownership of the mark and intra-group guarantees were treated as international transactions capable of arm's length adjustment. The 10% risk adjustment linked to the private equity investment was rejected as unsupported by the factual record and the investment price was treated as the best market indicator. Case-Laws Income Tax Thu, 10 Dec 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=401717