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...
Indexed cost of improvement claimed on flats received under a joint development arrangement requires evidence of actual improvement works and related payments. Construction costs were contractually borne by the developer, and the flats were sold in the semi-furnished condition received from the developer. Quotations and estimates for proposed additional work did not establish material purchases, labour payments, or execution of improvements. The NALA component was also unsupported. Consequently, the claimed indexed cost of improvement was disallowed, and the appeal was dismissed.
Indexed cost of improvement claimed on flats received under a joint development arrangement requires evidence of actual improvement works and related payments. Construction costs were contractually borne by the developer, and the flats were sold in the semi-furnished condition received from the developer. Quotations and estimates for proposed additional work did not establish material purchases, labour payments, or execution of improvements. The NALA component was also unsupported. Consequently, the claimed indexed cost of improvement was disallowed, and the appeal was dismissed.
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