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...
Revised post-survey construction cost estimates, TDR and development rights allocation, and GST impact on project cost under the Percentage of Completion Method depended on detailed factual verification. The text notes that the revised projections were linked to changes in floor plans, phase-wise utilisation of development rights, denial of input tax credit under the revised GST scheme, and consistency of revenue recognition with registered agreements. It records that broad explanations and estimated workings were insufficient, so the revised computation could not be finally accepted without examining the factual foundation. The disputed additions were therefore set aside and the matter was remanded for de novo verification and fresh decision for both assessment years.
Revised post-survey construction cost estimates, TDR and development rights allocation, and GST impact on project cost under the Percentage of Completion Method depended on detailed factual verification. The text notes that the revised projections were linked to changes in floor plans, phase-wise utilisation of development rights, denial of input tax credit under the revised GST scheme, and consistency of revenue recognition with registered agreements. It records that broad explanations and estimated workings were insufficient, so the revised computation could not be finally accepted without examining the factual foundation. The disputed additions were therefore set aside and the matter was remanded for de novo verification and fresh decision for both assessment years.
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