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...
Cancellation of the original allotment and a subsequent fresh allotment to a different flat broke the link with the 2012 transaction; the later registered agreement was treated as a new transaction, so adoption of the earlier valuation date was rejected. The cited precedent was distinguished on facts, and the claim to use the 2012 allotment date for stamp duty valuation was not accepted. On the alternative issue, once the stamp valuation adopted by the authority was disputed and supporting valuation material was filed, the Assessing Officer was required to obtain a DVO report before making any addition. The matter was restored for DVO reference and recomputation after hearing.
Cancellation of the original allotment and a subsequent fresh allotment to a different flat broke the link with the 2012 transaction; the later registered agreement was treated as a new transaction, so adoption of the earlier valuation date was rejected. The cited precedent was distinguished on facts, and the claim to use the 2012 allotment date for stamp duty valuation was not accepted. On the alternative issue, once the stamp valuation adopted by the authority was disputed and supporting valuation material was filed, the Assessing Officer was required to obtain a DVO report before making any addition. The matter was restored for DVO reference and recomputation after hearing.
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