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...
Capital Gains - Whether land belonged to the ''HUF'' and not to the assessee? - there was no mentioned that the land was being sold by the assessee as Karta of 'HUF' - proceeds of the sale were also deposited/retained by the assessee in his individual capacity and further the land so purchased out of the proceeds of the sale was also in the name of the assessee in individual capacity - plea that the income/capital gains should have been assessed in the name of the 'HUF' seems to be an afterthought. - AT
Capital Gains - Whether land belonged to the ''HUF'' and not to the assessee? - there was no mentioned that the land was being sold by the assessee as Karta of 'HUF' - proceeds of the sale were also deposited/retained by the assessee in his individual capacity and further the land so purchased out of the proceeds of the sale was also in the name of the assessee in individual capacity - plea that the income/capital gains should have been assessed in the name of the 'HUF' seems to be an afterthought. - AT
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