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 computation - cost of acquisition relates back to date of transfer through will/family settlement to beneficiary. Determination of indexed cost of acquisition for residential property acquired through family settlement. Additional evidence not admissible before ITAT without following rules. Family settlement is not a transfer, cost of acquisition relates back to previous owner's acquisition. Family settlement need not be registered if recording prior arrangement. For capital gains, cost inflation index calculated from year property acquired by previous owner through registered deed. Family arrangement does not involve transfer, hence no capital gains tax. Calculation based on indexed cost from previous owner's acquisition date, even if will disregarded. Order of CIT(A) upheld, decided in favor of assessee.
Capital gains computation - cost of acquisition relates back to date of transfer through will/family settlement to beneficiary. Determination of indexed cost of acquisition for residential property acquired through family settlement. Additional evidence not admissible before ITAT without following rules. Family settlement is not a transfer, cost of acquisition relates back to previous owner's acquisition. Family settlement need not be registered if recording prior arrangement. For capital gains, cost inflation index calculated from year property acquired by previous owner through registered deed. Family arrangement does not involve transfer, hence no capital gains tax. Calculation based on indexed cost from previous owner's acquisition date, even if will disregarded. Order of CIT(A) upheld, decided in favor of assessee.
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