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...
Deduction under section 48(i) was confined to expenditure incurred wholly and exclusively in connection with the transfer, and the assessee had to prove that proximate nexus. Travel and professional charges said to relate to execution of the sale deed required fresh verification, while expenditure incurred long before the transfer or attributable to other persons was not automatically deductible. One-time maintenance, electricity and water deposits were treated as part of the cost of acquisition of the flat because possession depended on those payments. Interest on the loan used to purchase the property was also allowed as cost of acquisition, with indexation, since it had not been claimed earlier as house property deduction.
Deduction under section 48(i) was confined to expenditure incurred wholly and exclusively in connection with the transfer, and the assessee had to prove that proximate nexus. Travel and professional charges said to relate to execution of the sale deed required fresh verification, while expenditure incurred long before the transfer or attributable to other persons was not automatically deductible. One-time maintenance, electricity and water deposits were treated as part of the cost of acquisition of the flat because possession depended on those payments. Interest on the loan used to purchase the property was also allowed as cost of acquisition, with indexation, since it had not been claimed earlier as house property deduction.
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