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 on Account of LTCG u/s 50C - The appellant contended that the property was a litigated property, and thus not possible to sell at market rate, arguing that the provisions of section 50C should not apply. The appellant also highlighted that the difference between the valuation adopted by the Stamp Valuation Authority and that declared by the appellant was less than 10%, suggesting that the value declared by the appellant should be accepted. The ITAT, referring to a similar case involving Bhojison Infrastructure Pvt. Ltd., where the tribunal allowed the appeal favoring the appellant, found that the appellant's case was directly covered by this decision.
Addition on Account of LTCG u/s 50C - The appellant contended that the property was a litigated property, and thus not possible to sell at market rate, arguing that the provisions of section 50C should not apply. The appellant also highlighted that the difference between the valuation adopted by the Stamp Valuation Authority and that declared by the appellant was less than 10%, suggesting that the value declared by the appellant should be accepted. The ITAT, referring to a similar case involving Bhojison Infrastructure Pvt. Ltd., where the tribunal allowed the appeal favoring the appellant, found that the appellant's case was directly covered by this decision.
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