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...
Slump sale u/s 50B or not - Fresh Claim that transaction not liable to capital gain tax - investment in Tax Savings Bonds u/s 54EC - AO, CIT(A) and the Tribunal committed a fundamental error in shutting out the contention raised by the assessee solely on the ground that the assessee approached the Bond Issuing Authorities for availing the benefit u/s 54EC. A careful reading of the submissions made by the assessee before the AO would make things further clear. - There is no estoppel on the part of the assessee to pursue their claim and accordingly, we reject the argument of the Revenue in this regard. - HC
Slump sale u/s 50B or not - Fresh Claim that transaction not liable to capital gain tax - investment in Tax Savings Bonds u/s 54EC - AO, CIT(A) and the Tribunal committed a fundamental error in shutting out the contention raised by the assessee solely on the ground that the assessee approached the Bond Issuing Authorities for availing the benefit u/s 54EC. A careful reading of the submissions made by the assessee before the AO would make things further clear. - There is no estoppel on the part of the assessee to pursue their claim and accordingly, we reject the argument of the Revenue in this regard. - HC
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