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 - deduction u/s 54F - Ownership of more than one residential house at the time of sale of an original asset - The tribunal sided with the interpretation that joint ownership of property does not equate to full ownership, and hence does not disqualify the assessee from availing the deduction under section 54F of the Income Tax Act, following the reasoning of the Madras High Court over that of the Karnataka High Court.
LTCG - deduction u/s 54F - Ownership of more than one residential house at the time of sale of an original asset - The tribunal sided with the interpretation that joint ownership of property does not equate to full ownership, and hence does not disqualify the assessee from availing the deduction under section 54F of the Income Tax Act, following the reasoning of the Madras High Court over that of the Karnataka High Court.
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