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...
Revision u/s 263 - error noted by the CIT that sale of properties by the assessee during the year was not examined by the AO vis-à-vis its stamp duty value for the purpose of invoking section 43CA - The appellant challenges the validity of the PCIT's directions, particularly regarding property transactions and stamp duty valuations under section 43CA. The ITAT ultimately rules in favor of the appellant, finding no error in the AO's assessment order and determining that the PCIT's directions were beyond the scope of revenue authorities' powers. Additionally, it clarifies the limited role of revenue authorities in questioning stamp duty valuations under section 43CA.
Revision u/s 263 - error noted by the CIT that sale of properties by the assessee during the year was not examined by the AO vis-à-vis its stamp duty value for the purpose of invoking section 43CA - The appellant challenges the validity of the PCIT's directions, particularly regarding property transactions and stamp duty valuations under section 43CA. The ITAT ultimately rules in favor of the appellant, finding no error in the AO's assessment order and determining that the PCIT's directions were beyond the scope of revenue authorities' powers. Additionally, it clarifies the limited role of revenue authorities in questioning stamp duty valuations under section 43CA.
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