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...
Enhancement of Capital Gain - Initially the value was taken as determined by the Sub-Registrar - Later, on objection raised by asessee, matter was referred to DVO - Application of section 50C, since the land is in Dark Zone - DVO has taken excessive rate without considering the average rate per Bigha which is more than double of prevailing Market rate - In addition to cost of boundary wall as taken by the DVO also considered for cost of acquisition - Relief granted to the assessee - AT
Enhancement of Capital Gain - Initially the value was taken as determined by the Sub-Registrar - Later, on objection raised by asessee, matter was referred to DVO - Application of section 50C, since the land is in Dark Zone - DVO has taken excessive rate without considering the average rate per Bigha which is more than double of prevailing Market rate - In addition to cost of boundary wall as taken by the DVO also considered for cost of acquisition - Relief granted to the assessee - AT
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