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...
Additions u/s 56(2)(vii)(b) - purchase of immovable property - difference in value as per stamp duty valuation - since the Sale Deed itself got cancelled vide Cancellation Deed dated 26.02.2013 and the entire sale consideration was repaid to the assessee. Thus the question of invoking Section 56(2)(vii)(b) does not arise - AT
Additions u/s 56(2)(vii)(b) - purchase of immovable property - difference in value as per stamp duty valuation - since the Sale Deed itself got cancelled vide Cancellation Deed dated 26.02.2013 and the entire sale consideration was repaid to the assessee. Thus the question of invoking Section 56(2)(vii)(b) does not arise - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4801
Join Channel
TaxTMI 
