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...
Enhancement in reassessment could not bring to tax long-term capital gain from sale of the Manesar property as a new source of income when reopening was confined to unexplained investment in the Panchkula property; the Tribunal held that appellate enhancement does not extend to an altogether new source and deleted the addition. It also held that the Manesar asset was a residential house property, supported by the sale deed, occupation certificate, approved plans and loan records, so indexed cost of construction or improvement was allowable. On the exemption claim, substantial investment in a new residential house within the prescribed period entitled the assessee to deduction under sections 54/54F despite no deposit in the Capital Gain Account Scheme.
Enhancement in reassessment could not bring to tax long-term capital gain from sale of the Manesar property as a new source of income when reopening was confined to unexplained investment in the Panchkula property; the Tribunal held that appellate enhancement does not extend to an altogether new source and deleted the addition. It also held that the Manesar asset was a residential house property, supported by the sale deed, occupation certificate, approved plans and loan records, so indexed cost of construction or improvement was allowable. On the exemption claim, substantial investment in a new residential house within the prescribed period entitled the assessee to deduction under sections 54/54F despite no deposit in the Capital Gain Account Scheme.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
