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...
Enforceable rights in a specific residential flat can satisfy the requirement of purchase for beneficial exemption relief, so long as the investment is made within the prescribed period and the later conveyance only regularises an earlier arrangement. Capital gains arising from an asset gifted to a spouse can be clubbed in the transferor's hands because "income" in the clubbing provision includes capital gains; once clubbed, the corresponding exemption attached to the spouse's residential investment must also be allowed to avoid distorted computation. Transfer expenses actually incurred and proved by invoices and bank records were allowed in full under the computation provisions, and were not to be reduced merely by reference to ownership share.
Enforceable rights in a specific residential flat can satisfy the requirement of purchase for beneficial exemption relief, so long as the investment is made within the prescribed period and the later conveyance only regularises an earlier arrangement. Capital gains arising from an asset gifted to a spouse can be clubbed in the transferor's hands because "income" in the clubbing provision includes capital gains; once clubbed, the corresponding exemption attached to the spouse's residential investment must also be allowed to avoid distorted computation. Transfer expenses actually incurred and proved by invoices and bank records were allowed in full under the computation provisions, and were not to be reduced merely by reference to ownership share.
Note: It is a system-generated summary and is for quick reference only.
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