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...
Capital gains exemption u/s 54F denied due to non-completion of construction within the stipulated period. The assessee entered into a Joint Development Agreement (JDA), receiving a residential villa in exchange for a plot of land. Despite a delay of over 7 years in completing construction against the 3-year period u/s 54F, the assessee failed to substantiate the explanation of a dispute among partners. No evidence was provided to demonstrate efforts made by the assessee to enforce rights under the agreement or ensure timely completion. Lack of vigilance and failure to exercise due diligence resulted in the dismissal of appeals by the Appellate Tribunal.
Capital gains exemption u/s 54F denied due to non-completion of construction within the stipulated period. The assessee entered into a Joint Development Agreement (JDA), receiving a residential villa in exchange for a plot of land. Despite a delay of over 7 years in completing construction against the 3-year period u/s 54F, the assessee failed to substantiate the explanation of a dispute among partners. No evidence was provided to demonstrate efforts made by the assessee to enforce rights under the agreement or ensure timely completion. Lack of vigilance and failure to exercise due diligence resulted in the dismissal of appeals by the Appellate Tribunal.
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