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 54 capital-gains exemption remains available where capital gains are invested in a new residential house within the prescribed period, even if the unutilised amount was not deposited in the Capital Gains Account Scheme before the return-filing due date. Treating section 54 as a beneficial provision, the Tribunal regarded the deposit requirement as procedural where the substantive investment condition was met. The taxpayer's share in the jointly acquired property exceeded the capital gain and the purchase occurred before the extended return-filing due date. Accordingly, the section 54 deduction was allowed and the disallowance was deleted.
Section 54 capital-gains exemption remains available where capital gains are invested in a new residential house within the prescribed period, even if the unutilised amount was not deposited in the Capital Gains Account Scheme before the return-filing due date. Treating section 54 as a beneficial provision, the Tribunal regarded the deposit requirement as procedural where the substantive investment condition was met. The taxpayer's share in the jointly acquired property exceeded the capital gain and the purchase occurred before the extended return-filing due date. Accordingly, the section 54 deduction was allowed and the disallowance was deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
