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 Appellate Tribunal addressed the issue of Long-Term Capital Gains (LTCG) on the sale of agricultural land, focusing on the property's location in relation to municipal limits u/s 2(14). The Tribunal considered the distance of the land from a specific landmark as confirmed by Income-tax Department inspectors and Tehsildar. The assessee argued that the distance should be calculated based on the municipal limits in place before a certain date, emphasizing the lack of subsequent notifications expanding the limits. Consequently, the Tribunal allowed the assessee's appeal, ruling that the land in question did not qualify as a capital asset for tax purposes.
The Appellate Tribunal addressed the issue of Long-Term Capital Gains (LTCG) on the sale of agricultural land, focusing on the property's location in relation to municipal limits u/s 2(14). The Tribunal considered the distance of the land from a specific landmark as confirmed by Income-tax Department inspectors and Tehsildar. The assessee argued that the distance should be calculated based on the municipal limits in place before a certain date, emphasizing the lack of subsequent notifications expanding the limits. Consequently, the Tribunal allowed the assessee's appeal, ruling that the land in question did not qualify as a capital asset for tax purposes.
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