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 upheld the AO and CIT(A)'s adoption of the stamp duty value of Rs.67,14,284 as full value of consideration under s.50C, finding no infirmity and noting no request for DVO reference. On s.54 exemption, ITAT accepted in principle the assessee's asserted 2:1 contribution ratio to the new residential property and directed the AO to verify actual contributions of the assessee and spouse and grant exemption proportionately if substantiated. Regarding indexed cost of improvements, ITAT found the absence of bank entry not determinative given the antiquity of the works and directed the AO to allow the claimed indexed improvement cost if contractor bills and supporting evidence credibly establish payment.
ITAT upheld the AO and CIT(A)'s adoption of the stamp duty value of Rs.67,14,284 as full value of consideration under s.50C, finding no infirmity and noting no request for DVO reference. On s.54 exemption, ITAT accepted in principle the assessee's asserted 2:1 contribution ratio to the new residential property and directed the AO to verify actual contributions of the assessee and spouse and grant exemption proportionately if substantiated. Regarding indexed cost of improvements, ITAT found the absence of bank entry not determinative given the antiquity of the works and directed the AO to allow the claimed indexed improvement cost if contractor bills and supporting evidence credibly establish payment.
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