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...
Payments made by a co-owner to occupants for vacating property before sale were treated as allowable in computing capital gains because the evidence showed they were incurred to secure vacant possession and facilitate transfer of an unencumbered, alienable title. The Tribunal accepted contemporaneous cheque records, receipts, affidavits and utility bills, and held the claim could not be rejected merely on suspicion or as an afterthought without rebuttal inquiry. Such eviction-related payments were regarded as part of the cost of acquisition or as expenditure wholly and exclusively in connection with the transfer, and the capital gains were directed to be recomputed accordingly.
Payments made by a co-owner to occupants for vacating property before sale were treated as allowable in computing capital gains because the evidence showed they were incurred to secure vacant possession and facilitate transfer of an unencumbered, alienable title. The Tribunal accepted contemporaneous cheque records, receipts, affidavits and utility bills, and held the claim could not be rejected merely on suspicion or as an afterthought without rebuttal inquiry. Such eviction-related payments were regarded as part of the cost of acquisition or as expenditure wholly and exclusively in connection with the transfer, and the capital gains were directed to be recomputed accordingly.
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