Revenue's Concerns on Party Relationship Examined; Section 4(4)(c) Test Required for Conclusion.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....Valuation - related party transaction - The revenue’s concern in examining whether the parties were related might be justified; however, it could not have concluded that such relationship, as is contemplated by Section 4(4)(c) could have been inferred, without applying the proper test. - SC....