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...
ITAT reversed CIT(A)'s addition under s.69 regarding unexplained property investment, accepting loan from assessee's mother as legitimate source after verification of her creditworthiness in reopened assessment. On interest disallowance under s.24, ITAT directed AO to verify if assessee's investment from borrowed funds was limited to their ownership share. Interest deduction permitted only on borrowed funds used for initial property investment up to assessee's share portion, following prudent investment principle. Subsequent investments, even if from borrowed funds, deemed ineligible for s.24 interest deduction. Matter remanded to AO for verification of fund utilization patterns in bank accounts and determination of allowable interest based on initial investment share.
ITAT reversed CIT(A)'s addition under s.69 regarding unexplained property investment, accepting loan from assessee's mother as legitimate source after verification of her creditworthiness in reopened assessment. On interest disallowance under s.24, ITAT directed AO to verify if assessee's investment from borrowed funds was limited to their ownership share. Interest deduction permitted only on borrowed funds used for initial property investment up to assessee's share portion, following prudent investment principle. Subsequent investments, even if from borrowed funds, deemed ineligible for s.24 interest deduction. Matter remanded to AO for verification of fund utilization patterns in bank accounts and determination of allowable interest based on initial investment share.
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