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...
Addition u/s 50C r.w.s. 56(2)(vii) (b) - the buyer of the property - The Tribunal (ITAT) ruled that since the assesses were buyers, Section 50C did not apply, and Section 56(2)(vii)(b) did not apply as the property was not acquired without consideration. The retrospective application of Section 56(2)(vii)(b) was also rejected. Additionally, the Tribunal found no grounds for addition under Section 69C, as no show cause notice was issued and the initial addition was not sustained. Consequently, the appeals by both assesses were allowed. Additionally, the Tribunal found no grounds for addition under Section 69C, as no show cause notice was issued and the initial addition was not sustained.
Addition u/s 50C r.w.s. 56(2)(vii) (b) - the buyer of the property - The Tribunal (ITAT) ruled that since the assesses were buyers, Section 50C did not apply, and Section 56(2)(vii)(b) did not apply as the property was not acquired without consideration. The retrospective application of Section 56(2)(vii)(b) was also rejected. Additionally, the Tribunal found no grounds for addition under Section 69C, as no show cause notice was issued and the initial addition was not sustained. Consequently, the appeals by both assesses were allowed. Additionally, the Tribunal found no grounds for addition under Section 69C, as no show cause notice was issued and the initial addition was not sustained.
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