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...
Deduction u/s 54 - The agreement to purchase new house property never fructified into registered Sale Deed till date - till actual conveyance happens, it could not be said that the assessee has purchased the houses property. Another fact to be noted is that the agreement has never fructified into registered sale deed till date despite the fact that the assessee has paid full consideration of Rs.165 Lacs and the document was executed on 30-03-2012. No valid circumstances which have impeded the registration of final deed have been adduced by the assessee. - the unregistered document as entered into by the assessee could not be considered as fulfilment of requirement of Sec.54 - AT
Deduction u/s 54 - The agreement to purchase new house property never fructified into registered Sale Deed till date - till actual conveyance happens, it could not be said that the assessee has purchased the houses property. Another fact to be noted is that the agreement has never fructified into registered sale deed till date despite the fact that the assessee has paid full consideration of Rs.165 Lacs and the document was executed on 30-03-2012. No valid circumstances which have impeded the registration of final deed have been adduced by the assessee. - the unregistered document as entered into by the assessee could not be considered as fulfilment of requirement of Sec.54 - AT
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