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 adjudicated on the following issues: 1. Cost of acquisition for computing long-term capital gains on sale of ancestral agricultural land: The assessee's valuation report was found unreliable. The matter was remanded to the Assessing Officer to refer it to the District Valuation Officer (DVO) to determine the correct market value as on 01.04.1981, after considering the assessee's objections. 2. Denial of deduction u/s 54F for purchase of new residential property: The ITAT upheld the disallowance, as the assessee failed to establish that a residential house was purchased within the stipulated time. 3. Date of acquisition of new property for Section 54F: The ITAT accepted the assessee's contention that the investment date should be considered as 26.07.2017, when the agreement was executed and full payment was made, despite delayed registration. 4. Addition for unexplained cash deposits in bank account: The ITAT treated cash deposits up to Rs. 15.48 lakhs as explained from agricultural income but confirmed the addition of Rs. 9 lakhs for unexplained cash deposits during demonetization.
The ITAT adjudicated on the following issues: 1. Cost of acquisition for computing long-term capital gains on sale of ancestral agricultural land: The assessee's valuation report was found unreliable. The matter was remanded to the Assessing Officer to refer it to the District Valuation Officer (DVO) to determine the correct market value as on 01.04.1981, after considering the assessee's objections. 2. Denial of deduction u/s 54F for purchase of new residential property: The ITAT upheld the disallowance, as the assessee failed to establish that a residential house was purchased within the stipulated time. 3. Date of acquisition of new property for Section 54F: The ITAT accepted the assessee's contention that the investment date should be considered as 26.07.2017, when the agreement was executed and full payment was made, despite delayed registration. 4. Addition for unexplained cash deposits in bank account: The ITAT treated cash deposits up to Rs. 15.48 lakhs as explained from agricultural income but confirmed the addition of Rs. 9 lakhs for unexplained cash deposits during demonetization.
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