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...
In the case before ITAT Delhi, the issue was the admissibility of additional evidence related to Long Term Capital Gains (LTCG) and deduction under section 54F. The assessee submitted evidence to prove that the agricultural land sold was not a capital asset and that the sale consideration was reinvested as per section 54F. The Tribunal held that the additional evidence should be considered under Rule 46A, despite not being presented before the Assessing Officer (AO). The CIT(A) erred in not admitting the evidence, citing a Supreme Court decision. The Tribunal emphasized that the CIT(A) has powers equal to the AO and can accept additional claims without the need for the assessee to revise the return. The appeal was allowed for statistical purposes.
In the case before ITAT Delhi, the issue was the admissibility of additional evidence related to Long Term Capital Gains (LTCG) and deduction under section 54F. The assessee submitted evidence to prove that the agricultural land sold was not a capital asset and that the sale consideration was reinvested as per section 54F. The Tribunal held that the additional evidence should be considered under Rule 46A, despite not being presented before the Assessing Officer (AO). The CIT(A) erred in not admitting the evidence, citing a Supreme Court decision. The Tribunal emphasized that the CIT(A) has powers equal to the AO and can accept additional claims without the need for the assessee to revise the return. The appeal was allowed for statistical purposes.
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