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 gain computation - Exemption u/s 54 - The claim of the assessee is supported by the agreement, receipt and name appearing in the bank statement of the contractor. CIT(A) merely stated his comments and there is no controverted finding on the documents in the remand report and the contentions raised by the CIT(A) were not verified by the ld. AO nor the finding is appearing in the order of the CIT(A) that the ld. AO has commented on these documents. The assessee was not given an opportunity to refuted these allegations so made. - Claim of the assessee for an amount cannot be disbelieved - AT
Capital gain computation - Exemption u/s 54 - The claim of the assessee is supported by the agreement, receipt and name appearing in the bank statement of the contractor. CIT(A) merely stated his comments and there is no controverted finding on the documents in the remand report and the contentions raised by the CIT(A) were not verified by the ld. AO nor the finding is appearing in the order of the CIT(A) that the ld. AO has commented on these documents. The assessee was not given an opportunity to refuted these allegations so made. - Claim of the assessee for an amount cannot be disbelieved - AT
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