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 assessee undervalued sales in books compared to market value of flats. Received advances per agreement, executed sale deeds later at agreement value. No addition under sec 43CA as part consideration received by cheque based on agreement. ITAT directed AO to delete addition. Excess payment to purchaser not interest, no TDS obligation per Beacon Projects case. Amount paid for surrender of rights not interest, no TDS obligation. Sec 40(a)(ia) not applicable. Decided in favor of assessee.
The assessee undervalued sales in books compared to market value of flats. Received advances per agreement, executed sale deeds later at agreement value. No addition under sec 43CA as part consideration received by cheque based on agreement. ITAT directed AO to delete addition. Excess payment to purchaser not interest, no TDS obligation per Beacon Projects case. Amount paid for surrender of rights not interest, no TDS obligation. Sec 40(a)(ia) not applicable. Decided in favor of assessee.
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