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...
The ITAT Chandigarh considered a revision u/s 263 by CIT regarding the period of limitation for completing requisite action. The assessment order was passed on 18/02/2014, and any issues requiring revision should have been addressed by 31/03/2016, within two years from the end of the relevant financial year. The revisionary order was found valid for transfer expenses, CLU charges, and deduction u/s 54F arising from reassessment. However, the revisionary proceedings related to the sale of land in District Solan were deemed barred by limitation as they pertained to the original assessment, not the reassessment. The availability of documentary evidence for transfer expenses and CLU charges was confirmed, and the AO's decision was upheld as not prejudicial to revenue. The deduction u/s 54F was restricted to Rs. 30,49,998 as determined by the Ld. Pr. CIT. The Assessee's appeal was partly allowed.
The ITAT Chandigarh considered a revision u/s 263 by CIT regarding the period of limitation for completing requisite action. The assessment order was passed on 18/02/2014, and any issues requiring revision should have been addressed by 31/03/2016, within two years from the end of the relevant financial year. The revisionary order was found valid for transfer expenses, CLU charges, and deduction u/s 54F arising from reassessment. However, the revisionary proceedings related to the sale of land in District Solan were deemed barred by limitation as they pertained to the original assessment, not the reassessment. The availability of documentary evidence for transfer expenses and CLU charges was confirmed, and the AO's decision was upheld as not prejudicial to revenue. The deduction u/s 54F was restricted to Rs. 30,49,998 as determined by the Ld. Pr. CIT. The Assessee's appeal was partly allowed.
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