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 actual contractual rent under registered leave-and-license arrangements, together with separately agreed commercial amenity charges, could not be replaced by an enhanced annual letting value absent cogent material of suppressed rent, sham transactions, or unaccounted consideration; the addition under section 23(1)(a) was deleted. It also held that interest on borrowed capital used to acquire let-out commercial property was deductible under section 24(b) because the borrowings had a direct nexus with acquisition and the Revenue could not deny relief while taxing the property under the head income from house property; the disallowance was deleted. In the absence of exempt income, section 14A and Rule 8D could not be invoked, and the Finance Act 2022 Explanation was treated as prospective.
ITAT held that actual contractual rent under registered leave-and-license arrangements, together with separately agreed commercial amenity charges, could not be replaced by an enhanced annual letting value absent cogent material of suppressed rent, sham transactions, or unaccounted consideration; the addition under section 23(1)(a) was deleted. It also held that interest on borrowed capital used to acquire let-out commercial property was deductible under section 24(b) because the borrowings had a direct nexus with acquisition and the Revenue could not deny relief while taxing the property under the head income from house property; the disallowance was deleted. In the absence of exempt income, section 14A and Rule 8D could not be invoked, and the Finance Act 2022 Explanation was treated as prospective.
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