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...
Transferable development rights received in exchange for surrendering land and building to a municipal authority have an ascertainable cost of acquisition: the cost attributable to the surrendered property. Their subsequent cash sale is therefore chargeable as capital gains, unlike self-generated development rights arising without transfer of an identified asset. Where a scrutiny notice merely identifies a refund claim for verification and does not specify limited scrutiny, the assessment may extend to the taxability of such rights. Non-taxation of similar receipts in another taxpayer's assessment does not create parity or estoppel against correct application of tax law. Capital gains must be recomputed after allowing the attributable acquisition cost.
Transferable development rights received in exchange for surrendering land and building to a municipal authority have an ascertainable cost of acquisition: the cost attributable to the surrendered property. Their subsequent cash sale is therefore chargeable as capital gains, unlike self-generated development rights arising without transfer of an identified asset. Where a scrutiny notice merely identifies a refund claim for verification and does not specify limited scrutiny, the assessment may extend to the taxability of such rights. Non-taxation of similar receipts in another taxpayer's assessment does not create parity or estoppel against correct application of tax law. Capital gains must be recomputed after allowing the attributable acquisition cost.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4801
Join Channel
TaxTMI 
