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 - Disallowance u/s 54 - construction of new house begun before the sale of the old house - The Tribunal emphasized that section 54 does not mandate the utilization of sale proceeds from the original asset for the purchase or construction of the new asset. - Referring to decisions from various High Courts, the Tribunal held that exemption under section 54F is applicable even if the investment is made from borrowed funds, as long as it meets the stipulated timeline. - Regarding the timeline for construction and possession, the Tribunal reiterated that the relevant date should be determined based on when the builder offered possession or cleared the balance dues, rather than earlier stages of construction.
LTCG - Disallowance u/s 54 - construction of new house begun before the sale of the old house - The Tribunal emphasized that section 54 does not mandate the utilization of sale proceeds from the original asset for the purchase or construction of the new asset. - Referring to decisions from various High Courts, the Tribunal held that exemption under section 54F is applicable even if the investment is made from borrowed funds, as long as it meets the stipulated timeline. - Regarding the timeline for construction and possession, the Tribunal reiterated that the relevant date should be determined based on when the builder offered possession or cleared the balance dues, rather than earlier stages of construction.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4801
Join Channel
TaxTMI 
