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 - Valuation of the property sold by the assessee - reference to DVO - ITAT noted that the reference made by the AO to the VO was not in accordance with the relevant provisions of the Act. - The Tribunal analyzed the provisions of section 55A of the Act, both before and after the amendment effective from 01-07-2012. It determined that the amendment was not applicable to the relevant assessment year and, therefore, the reference made by the AO to the VO was not valid.
Capital gain - Valuation of the property sold by the assessee - reference to DVO - ITAT noted that the reference made by the AO to the VO was not in accordance with the relevant provisions of the Act. - The Tribunal analyzed the provisions of section 55A of the Act, both before and after the amendment effective from 01-07-2012. It determined that the amendment was not applicable to the relevant assessment year and, therefore, the reference made by the AO to the VO was not valid.
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