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 under sections 45 and 48 are to be computed asset-wise, so each transfer of a long-term capital asset is a distinct source of gain. On that basis, section 54 exemption must be examined with reference to each transferred residential house and not by aggregating gains from multiple sales into one composite figure for investment in only one new house. The proviso allowing investment in two residential houses, where the capital gain does not exceed the prescribed limit, also operates transfer-wise. As the assessee sold multiple flats and invested in several residential houses, the statutory condition was not breached and the full section 54 claim was allowed; the earlier consistent treatment of the same claim supported this result.
Capital gains under sections 45 and 48 are to be computed asset-wise, so each transfer of a long-term capital asset is a distinct source of gain. On that basis, section 54 exemption must be examined with reference to each transferred residential house and not by aggregating gains from multiple sales into one composite figure for investment in only one new house. The proviso allowing investment in two residential houses, where the capital gain does not exceed the prescribed limit, also operates transfer-wise. As the assessee sold multiple flats and invested in several residential houses, the statutory condition was not breached and the full section 54 claim was allowed; the earlier consistent treatment of the same claim supported this result.
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