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...
Section 54F permits exemption based on investment in a residential house through purchase, construction, or a combination of both. The cost of the new asset can include bona fide expenditure incurred after purchase for reconstruction, alteration, renovation and improvements that make the house fit for residence. Habitability of the purchased house and reconstruction expenditure exceeding its purchase cost do not independently restrict the exemption, as no statutory ceiling applies to construction quality or amenities. Expenditure on independent comfort items remains excluded. Where reconstruction expenditure is genuine and not linked to excluded items, the aggregate purchase and reconstruction cost qualifies for the Section 54F exemption.
Section 54F permits exemption based on investment in a residential house through purchase, construction, or a combination of both. The cost of the new asset can include bona fide expenditure incurred after purchase for reconstruction, alteration, renovation and improvements that make the house fit for residence. Habitability of the purchased house and reconstruction expenditure exceeding its purchase cost do not independently restrict the exemption, as no statutory ceiling applies to construction quality or amenities. Expenditure on independent comfort items remains excluded. Where reconstruction expenditure is genuine and not linked to excluded items, the aggregate purchase and reconstruction cost qualifies for the Section 54F exemption.
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