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...
Deduction for capital gain on agricultural land was upheld where inspectors' post-transfer report and photographs were temporally remote, unnotified, and not authenticated, so they could not rebut revenue records showing the land was used for agriculture as on transfer. The tribunal found the revenue failed to discharge the onus of proving the land's non agricultural character, noted that meagre agricultural income does not change land character, and confirmed the appellate authority's allowance of the deduction under the relevant tax provision.
Deduction for capital gain on agricultural land was upheld where inspectors' post-transfer report and photographs were temporally remote, unnotified, and not authenticated, so they could not rebut revenue records showing the land was used for agriculture as on transfer. The tribunal found the revenue failed to discharge the onus of proving the land's non agricultural character, noted that meagre agricultural income does not change land character, and confirmed the appellate authority's allowance of the deduction under the relevant tax provision.
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