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...
Capital gains exemption for investment in a new residential property was allowed where the assessee had paid substantial consideration under an agreement to sell, taken possession, and committed the capital gains within the stipulated period. The later registration of the sale deed was not treated as fatal because the final conveyance acknowledged the earlier agreement, recorded the advance payment, and explained the delay by reference to the property being mortgaged and bank NOC not being obtained in time. The ITAT applied the principle that timely investment in the residential property, not mere postponement of formal registration, governs the relief and set aside the denial of exemption.
Capital gains exemption for investment in a new residential property was allowed where the assessee had paid substantial consideration under an agreement to sell, taken possession, and committed the capital gains within the stipulated period. The later registration of the sale deed was not treated as fatal because the final conveyance acknowledged the earlier agreement, recorded the advance payment, and explained the delay by reference to the property being mortgaged and bank NOC not being obtained in time. The ITAT applied the principle that timely investment in the residential property, not mere postponement of formal registration, governs the relief and set aside the denial of exemption.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
