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...
Exemption u/s 54EC - Assessee has not been able to raise any material contention to dispute this position. He has only submitted that the assessee wanted to invest the long- term capital gain in purchase of another residential property and unable to find the suitable property, he finally invested the amount in long- term capital gain bonds on 21. 01.2020. In my opinion, this aspect is irrelevant to decide the eligibility of assessee for exemption under section 54EC, which specifically provides that the investment in eligible bonds is required to be made by the assessee within a period of six months from the date of transfer of the long-term capital asset in order to claim the exemption on account of long- term capital gain - AT
Exemption u/s 54EC - Assessee has not been able to raise any material contention to dispute this position. He has only submitted that the assessee wanted to invest the long- term capital gain in purchase of another residential property and unable to find the suitable property, he finally invested the amount in long- term capital gain bonds on 21. 01.2020. In my opinion, this aspect is irrelevant to decide the eligibility of assessee for exemption under section 54EC, which specifically provides that the investment in eligible bonds is required to be made by the assessee within a period of six months from the date of transfer of the long-term capital asset in order to claim the exemption on account of long- term capital gain - AT
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