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 quashed the order passed by the Principal Commissioner of Income Tax (PCIT) u/s 263 of the Income Tax Act. The assessee was eligible for deduction u/s 54EC as the land was used for agricultural purposes in the preceding two years before its sale, as evident from the 7/12 extracts. The ITAT held that the Assessing Officer's conclusion accepting the assessee's claim was reasonable and not erroneous, and the PCIT failed to establish that the order was prejudicial to the Revenue's interests. The reference to the Valuation Officer was not mandatory, and the PCIT lacked authority to direct such a reference. The ITAT ruled in favor of the assessee, allowing the grounds raised.
The ITAT quashed the order passed by the Principal Commissioner of Income Tax (PCIT) u/s 263 of the Income Tax Act. The assessee was eligible for deduction u/s 54EC as the land was used for agricultural purposes in the preceding two years before its sale, as evident from the 7/12 extracts. The ITAT held that the Assessing Officer's conclusion accepting the assessee's claim was reasonable and not erroneous, and the PCIT failed to establish that the order was prejudicial to the Revenue's interests. The reference to the Valuation Officer was not mandatory, and the PCIT lacked authority to direct such a reference. The ITAT ruled in favor of the assessee, allowing the grounds raised.
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