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 assessee was held to be a "developer" and not merely a "works contractor" for the purposes of claiming deduction u/s 80-IA(4) of the Income Tax Act. The Tribunal allowed the assessee's claim for deduction u/s 80-IA(4) on the ground that the assessee had deployed its own funds, equipment, and had undertaken the risk and liability from the inception of the project till its transfer to the Airport Authority of India. The Tribunal concluded that a new infrastructure facility, in the form of a New Expandable Modular Integrated Terminal Building at Raja Bhoj Airport, Bhopal, had come into existence, similar to the case of NCC-MSKEL JV, where a new domestic arrival block at Sardar Vallabh Bhai Patel International Airport, Ahmedabad, was held to be a new infrastructure facility eligible for deduction u/s 80-IA(4).
The assessee was held to be a "developer" and not merely a "works contractor" for the purposes of claiming deduction u/s 80-IA(4) of the Income Tax Act. The Tribunal allowed the assessee's claim for deduction u/s 80-IA(4) on the ground that the assessee had deployed its own funds, equipment, and had undertaken the risk and liability from the inception of the project till its transfer to the Airport Authority of India. The Tribunal concluded that a new infrastructure facility, in the form of a New Expandable Modular Integrated Terminal Building at Raja Bhoj Airport, Bhopal, had come into existence, similar to the case of NCC-MSKEL JV, where a new domestic arrival block at Sardar Vallabh Bhai Patel International Airport, Ahmedabad, was held to be a new infrastructure facility eligible for deduction u/s 80-IA(4).
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