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...
Disallowance of claim u/s 54F - assessee did not purchase new house within the stipulated time of one year prior to the date of transfer of original asset - renovation to old house which was purchased before the date of transfer of original asset will not entitle the assessee to claim deduction u/s 54F
Disallowance of claim u/s 54F - assessee did not purchase new house within the stipulated time of one year prior to the date of transfer of original asset - renovation to old house which was purchased before the date of transfer of original asset will not entitle the assessee to claim deduction u/s 54F
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