Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
ITAT held that indexed cost of improvement for an old developed residential property could not be rejected merely because old bills and vouchers were unavailable. As the registered sale deed and stamp valuation records showed a substantial superstructure, the cost of construction and improvement had to be recomputed on a reasonable basis using the covered area and applicable PWD rates, with consequential indexation. On section 54, the Tribunal held that the assessee was entitled to deduction on the full eligible investment in the new leasehold residential property because the funds were wholly from the assessee and joint naming of the husband did not limit the claim. Optional club membership charges were excluded from eligible cost.
ITAT held that indexed cost of improvement for an old developed residential property could not be rejected merely because old bills and vouchers were unavailable. As the registered sale deed and stamp valuation records showed a substantial superstructure, the cost of construction and improvement had to be recomputed on a reasonable basis using the covered area and applicable PWD rates, with consequential indexation. On section 54, the Tribunal held that the assessee was entitled to deduction on the full eligible investment in the new leasehold residential property because the funds were wholly from the assessee and joint naming of the husband did not limit the claim. Optional club membership charges were excluded from eligible cost.
Note: It is a system-generated summary and is for quick reference only.