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...
Calculation of Capital Gain - Non-Resident - Applicability of section 144C - eligible assessee - The appellant contested the rejection of their valuation report and the adoption of circle rates, arguing that the valuation report should have been relied upon. Discrepancies in the calculation of capital gains, particularly concerning brokerage expenses and stamp duty, were also highlighted. The Tribunal found merit in several of the appellant's arguments, directing the AO to reconsider certain aspects and providing relief to the appellant.
Calculation of Capital Gain - Non-Resident - Applicability of section 144C - eligible assessee - The appellant contested the rejection of their valuation report and the adoption of circle rates, arguing that the valuation report should have been relied upon. Discrepancies in the calculation of capital gains, particularly concerning brokerage expenses and stamp duty, were also highlighted. The Tribunal found merit in several of the appellant's arguments, directing the AO to reconsider certain aspects and providing relief to the appellant.
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