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...
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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 held that the assessee is eligible to claim deduction u/s 54EC of the Income Tax Act for investment in bonds of the National Highway Authority of India (NHAI). The assessee had invested the advance money received towards the sale of a property in the specified NHAI bonds before the date of transfer. This is in line with Circular No. 359 and the Bombay High Court's decision in CIT vs. Subhash Vinayak Supnekar, which ruled that when an advance received under an agreement to sell a capital asset is invested in specified bonds, the benefit of Section 54EC is available. The Tribunal observed a direct nexus between the advance received and the investment made, thereby allowing the assessee's appeal.
The Appellate Tribunal held that the assessee is eligible to claim deduction u/s 54EC of the Income Tax Act for investment in bonds of the National Highway Authority of India (NHAI). The assessee had invested the advance money received towards the sale of a property in the specified NHAI bonds before the date of transfer. This is in line with Circular No. 359 and the Bombay High Court's decision in CIT vs. Subhash Vinayak Supnekar, which ruled that when an advance received under an agreement to sell a capital asset is invested in specified bonds, the benefit of Section 54EC is available. The Tribunal observed a direct nexus between the advance received and the investment made, thereby allowing the assessee's appeal.
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