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...
Jurisdictional objection under section 124(3) failed because the assessee, after receiving notice and participating in the assessment without protest, was treated as having accepted the AO's territorial jurisdiction. For LTCG computation, the Tribunal held that the cost of acquisition of converted land could not be restricted merely because part of the area was left for roads and drainage; the full claimed cost with indexation had to be allowed. Where seized cash and surrounding material showed receipt of on-money, substitution of declared consideration with valuation-based fair market value was upheld. Interest under sections 234A and 234B was deleted because seized cash available with the Revenue should have been adjusted, while section 234C was confined to any default before seizure.
Jurisdictional objection under section 124(3) failed because the assessee, after receiving notice and participating in the assessment without protest, was treated as having accepted the AO's territorial jurisdiction. For LTCG computation, the Tribunal held that the cost of acquisition of converted land could not be restricted merely because part of the area was left for roads and drainage; the full claimed cost with indexation had to be allowed. Where seized cash and surrounding material showed receipt of on-money, substitution of declared consideration with valuation-based fair market value was upheld. Interest under sections 234A and 234B was deleted because seized cash available with the Revenue should have been adjusted, while section 234C was confined to any default before seizure.
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