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...
LTCG - Denial of exemption u/s 54 - the ITAT observed that, for the purpose of claiming the benefit u/s 54 of the Act, within a period of one year before or two year after the date of transfer of old house, the tax payer should acquire another residential house or should construct a residential house within a specified period of three years from the date of transfer of old house. - The Tribunal held that t assessee has not fulfilled either of the conditions mentioned in Section 54, there is no error or infirmity in the orders of the Lower Authorities in denying the benefit of deduction to the assessee u/s 54.
LTCG - Denial of exemption u/s 54 - the ITAT observed that, for the purpose of claiming the benefit u/s 54 of the Act, within a period of one year before or two year after the date of transfer of old house, the tax payer should acquire another residential house or should construct a residential house within a specified period of three years from the date of transfer of old house. - The Tribunal held that t assessee has not fulfilled either of the conditions mentioned in Section 54, there is no error or infirmity in the orders of the Lower Authorities in denying the benefit of deduction to the assessee u/s 54.
Note: It is a system-generated summary and is for quick reference only.