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...
Deduction under section 54F was held allowable despite non-deposit of the unutilized capital gains in the Capital Gains Account Scheme before the return due date, because the assessee had actually invested the amount in purchase or construction of a residential house within the time permitted under section 54F(1). The Tribunal held that section 54F(4) applies where the assessee seeks to retain the unutilized amount while claiming exemption; it does not by itself defeat relief when the investment condition is otherwise satisfied. The disallowance was reversed and the Assessing Officer was directed to allow the deduction.
Deduction under section 54F was held allowable despite non-deposit of the unutilized capital gains in the Capital Gains Account Scheme before the return due date, because the assessee had actually invested the amount in purchase or construction of a residential house within the time permitted under section 54F(1). The Tribunal held that section 54F(4) applies where the assessee seeks to retain the unutilized amount while claiming exemption; it does not by itself defeat relief when the investment condition is otherwise satisfied. The disallowance was reversed and the Assessing Officer was directed to allow the deduction.
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