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 case pertains to the prohibition of benami property transactions and the applicability of amended provisions introduced by the Amending Act of 2016 to the Benami Transactions (Prohibition) Act, 1988. The key points are: The Initiating Officer (I.O.) attached an agricultural land, alleging it to be a benami transaction, but could not identify the beneficial owner. The Adjudicating Authority treated the transaction as falling u/s 2(9A) of the amended Act, despite it being prior to the 2016 amendment. The Supreme Court has clarified that the amended provisions have prospective application. Transactions prior to November 1, 2016, not covered by Section 2(9A) of the amended Act, are governed by the judgment in Union of India & Anr. vs. M/s. Ganpati Dealcom Pvt. Ltd. An exception may apply if the case falls u/s 2(9A) of the amended definition, as per the Appellate Tribunal's judgment in M/s. Prism Scan Express Pvt. Ltd.
The case pertains to the prohibition of benami property transactions and the applicability of amended provisions introduced by the Amending Act of 2016 to the Benami Transactions (Prohibition) Act, 1988. The key points are: The Initiating Officer (I.O.) attached an agricultural land, alleging it to be a benami transaction, but could not identify the beneficial owner. The Adjudicating Authority treated the transaction as falling u/s 2(9A) of the amended Act, despite it being prior to the 2016 amendment. The Supreme Court has clarified that the amended provisions have prospective application. Transactions prior to November 1, 2016, not covered by Section 2(9A) of the amended Act, are governed by the judgment in Union of India & Anr. vs. M/s. Ganpati Dealcom Pvt. Ltd. An exception may apply if the case falls u/s 2(9A) of the amended definition, as per the Appellate Tribunal's judgment in M/s. Prism Scan Express Pvt. Ltd.
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