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...
Payment to a tenant for taking over a building on lease cancellation was supported by the agreement, bank records, ledger entries and TDS documents, so ITAT accepted it as part of the building block of assets. The Tribunal held that the Assessing Officer could not recast the brought-forward written-down value by relying on assumptions from earlier years, especially when the block had been consistently carried forward in the books and returns and no contrary material was produced. It also noted that the earlier revaluation related to land, not the factory building. The restriction of the short-term capital loss was therefore unsustainable, and the loss claimed was allowed.
Payment to a tenant for taking over a building on lease cancellation was supported by the agreement, bank records, ledger entries and TDS documents, so ITAT accepted it as part of the building block of assets. The Tribunal held that the Assessing Officer could not recast the brought-forward written-down value by relying on assumptions from earlier years, especially when the block had been consistently carried forward in the books and returns and no contrary material was produced. It also noted that the earlier revaluation related to land, not the factory building. The restriction of the short-term capital loss was therefore unsustainable, and the loss claimed was allowed.
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