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 requires purchase of the new residential house within the statutory period, and an unregistered banakhat by itself was not enough to prove completion of purchase within that time frame. Because the substantial payment was made more than one year before transfer and the registered sale deed was executed beyond two years after transfer, the deduction could not be sustained on the existing record; the issue was restored for limited verification of the flow of funds and linkage with sale proceeds. The addition under section 69 also required fresh factual examination, as the bank statements and documentary evidence were not properly verified and it was unclear whether all material had been before the AO. Both matters were remanded.
Section 54F requires purchase of the new residential house within the statutory period, and an unregistered banakhat by itself was not enough to prove completion of purchase within that time frame. Because the substantial payment was made more than one year before transfer and the registered sale deed was executed beyond two years after transfer, the deduction could not be sustained on the existing record; the issue was restored for limited verification of the flow of funds and linkage with sale proceeds. The addition under section 69 also required fresh factual examination, as the bank statements and documentary evidence were not properly verified and it was unclear whether all material had been before the AO. Both matters were remanded.
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