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...
Disallowance of exemption claimed u/s 54EC - non filling ROI - investment made in REC - assessee has neither filed return of income u/s 139(1) of the Act, nor in response to the notice issued u/s 148 - The tribunal concluded that for claiming exemption under section 54EC of the Income Tax Act, it is not mandatory to file a return of income. - Even at the time of hearing the Ld. DR has not brought our attention to such provision of the Act, suggesting that it is mandatory, for claiming exemption u/s 54EC of the Act, to file the return of income. - AO directed to allow the benefit of exemption.
Disallowance of exemption claimed u/s 54EC - non filling ROI - investment made in REC - assessee has neither filed return of income u/s 139(1) of the Act, nor in response to the notice issued u/s 148 - The tribunal concluded that for claiming exemption under section 54EC of the Income Tax Act, it is not mandatory to file a return of income. - Even at the time of hearing the Ld. DR has not brought our attention to such provision of the Act, suggesting that it is mandatory, for claiming exemption u/s 54EC of the Act, to file the return of income. - AO directed to allow the benefit of exemption.
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