164 results for “transfer pricing”+ Section 2(47)(v)clear
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Bench: Shri Sanjay Garg & Dr. B.R.R. Kumar
section 2(47) of the IT Act, 1961. We also place reliance on the decision of CIT vs. Rasiklal Maneklal (HUF) (177 ITR 198)(SC) wherein the apex court held, affirming the decision of the High Court, that there was neither an "exchange" nor a "relinquishment" and no capital gains arose from the transaction. An "exchange" involves the transfer