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...
Nature of land - capital gain on sale of land - exemption u/s 10(37) - assessee's agricultural land was compulsorily acquired by following entire procedure prescribed under Land Acquisition Act - character of acquisition - Revenue contested the CIT(A)'s acceptance of 1947 as the year of transfer instead of 19.05.2014 (date of final award). - The Tribunal held that the peculiar circumstances warranted consideration of the land's acquisition date as 1947 for the purpose of exemption under Section 10(37), emphasizing the continuous possession by the state and non-alteration in land's status due to delayed compensation. - The ITAT observed that the land's character and use as agricultural at the time of its original acquisition in 1947 were crucial, dismissing the relevance of its status immediately before the compensation award in 2014 for the purposes of Section 10(37).
Nature of land - capital gain on sale of land - exemption u/s 10(37) - assessee's agricultural land was compulsorily acquired by following entire procedure prescribed under Land Acquisition Act - character of acquisition - Revenue contested the CIT(A)'s acceptance of 1947 as the year of transfer instead of 19.05.2014 (date of final award). - The Tribunal held that the peculiar circumstances warranted consideration of the land's acquisition date as 1947 for the purpose of exemption under Section 10(37), emphasizing the continuous possession by the state and non-alteration in land's status due to delayed compensation. - The ITAT observed that the land's character and use as agricultural at the time of its original acquisition in 1947 were crucial, dismissing the relevance of its status immediately before the compensation award in 2014 for the purposes of Section 10(37).
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4809 
Join Channel 
