Pure-agent exclusion fails where hotel booking facilitators receive third-party services themselves, making entire customer consideration taxable as r...
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...
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Capital-gains computation for an unquoted equity-share transfer uses the consideration actually received or accruing from that transfer; a notional value may replace it only under an express statutory fiction. The prescribed fair-market-value substitution did not apply where the declared consideration exceeded fair market value. Demat records and contemporaneous delivery instructions established completion of the earlier transfer, and later settlement of the purchaser's liability could not alter its transfer date or consideration. A subsequent transfer under a different ownership and contractual structure could not substitute its consideration for the earlier transaction, particularly where conditions had not crystallised the final price. The capital-gains addition was therefore deleted.
Capital-gains computation for an unquoted equity-share transfer uses the consideration actually received or accruing from that transfer; a notional value may replace it only under an express statutory fiction. The prescribed fair-market-value substitution did not apply where the declared consideration exceeded fair market value. Demat records and contemporaneous delivery instructions established completion of the earlier transfer, and later settlement of the purchaser's liability could not alter its transfer date or consideration. A subsequent transfer under a different ownership and contractual structure could not substitute its consideration for the earlier transaction, particularly where conditions had not crystallised the final price. The capital-gains addition was therefore deleted.
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