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...
Industrial gala sold - taxation as STCG or LTCG - The entire payment as per the agreement was in fact made before financial year 1998-99. Occupation certificate was also issued on 10.03.1998 - the keys were taken back by the assessee on 01.01.2005 - sale of the property in the year 2005 has to be treated as sale of long-term capital assets and gain has to be assessed as long-term-capital-gain - AT
Industrial gala sold - taxation as STCG or LTCG - The entire payment as per the agreement was in fact made before financial year 1998-99. Occupation certificate was also issued on 10.03.1998 - the keys were taken back by the assessee on 01.01.2005 - sale of the property in the year 2005 has to be treated as sale of long-term capital assets and gain has to be assessed as long-term-capital-gain - AT
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