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...
In a real estate anti-profiteering matter, the Tribunal accepted the DGAP report in full because the respondent unconditionally accepted the methodology, quantification and contravention finding, and the remaining profiteered amount for the period up to receipt of the Occupancy Certificate was ordered to be refunded to eligible homebuyers. It also upheld interest on the profiteered amount, holding that interest is payable from the dates of excess collection until actual refund. The penalty provision was held inapplicable because the alleged profiteering had ended before Section 171(3A) came into force, so no penalty was payable.
In a real estate anti-profiteering matter, the Tribunal accepted the DGAP report in full because the respondent unconditionally accepted the methodology, quantification and contravention finding, and the remaining profiteered amount for the period up to receipt of the Occupancy Certificate was ordered to be refunded to eligible homebuyers. It also upheld interest on the profiteered amount, holding that interest is payable from the dates of excess collection until actual refund. The penalty provision was held inapplicable because the alleged profiteering had ended before Section 171(3A) came into force, so no penalty was payable.
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