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 ITAT allowed the assessee's appeal, holding that the assumption of jurisdiction u/s 153C of the Income Tax Act by the Assessing Officer was vitiated due to a lack of proper 'satisfaction note'. The 'satisfaction note' lacked tangible and descriptive information, indicating a lack of application of mind. Consequently, the notice issued u/s 153C and the consequent assessment order were quashed. Additionally, regarding the valuation of a property, the ITAT accepted the assessee's contention and the District Valuation Officer's report, which was closer to the declared sale consideration. The significant difference between the sale consideration mentioned in the Agreement to Sale and the Sale Deed was deemed unconceivable and contrary to the estimated market value. The assessee's declared sale consideration was upheld in the absence of any contrary inquiry by the Revenue.
The ITAT allowed the assessee's appeal, holding that the assumption of jurisdiction u/s 153C of the Income Tax Act by the Assessing Officer was vitiated due to a lack of proper 'satisfaction note'. The 'satisfaction note' lacked tangible and descriptive information, indicating a lack of application of mind. Consequently, the notice issued u/s 153C and the consequent assessment order were quashed. Additionally, regarding the valuation of a property, the ITAT accepted the assessee's contention and the District Valuation Officer's report, which was closer to the declared sale consideration. The significant difference between the sale consideration mentioned in the Agreement to Sale and the Sale Deed was deemed unconceivable and contrary to the estimated market value. The assessee's declared sale consideration was upheld in the absence of any contrary inquiry by the Revenue.
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