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...
Section 54F relief was available where the assessee booked an under-construction flat, paid substantially the entire consideration within the statutory period, and obtained registration later. The Tribunal treated the transaction as falling within the construction limb of Section 54F, so the three-year period applied and delayed execution of the sale deed did not defeat the claim. It further held that, even on a purchase analysis, the critical factor was acquisition of substantial domain over the property through timely substantial payment, not the date of registration alone. On these facts, the deduction was allowed and the denial by the lower authorities was reversed.
Section 54F relief was available where the assessee booked an under-construction flat, paid substantially the entire consideration within the statutory period, and obtained registration later. The Tribunal treated the transaction as falling within the construction limb of Section 54F, so the three-year period applied and delayed execution of the sale deed did not defeat the claim. It further held that, even on a purchase analysis, the critical factor was acquisition of substantial domain over the property through timely substantial payment, not the date of registration alone. On these facts, the deduction was allowed and the denial by the lower authorities was reversed.
Note: It is a system-generated summary and is for quick reference only.