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...
LTCG - Deemed Sale Value - DVO was not justified in valuing the building, because the assessee was owner of the land only and the building was not constructed or owned by assessee and DVO also failed to appreciate that the property was on lease till 2040 and was only entitled to receive a sum of ₹ 10,000 per month as rent being co-owner - valuation of the property had to be made as per Rent Capitalization method
LTCG - Deemed Sale Value - DVO was not justified in valuing the building, because the assessee was owner of the land only and the building was not constructed or owned by assessee and DVO also failed to appreciate that the property was on lease till 2040 and was only entitled to receive a sum of ₹ 10,000 per month as rent being co-owner - valuation of the property had to be made as per Rent Capitalization method
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