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...
Section 54F relief was available because the Millennium Plaza property was treated as an office space and therefore a commercial property, not a residential house; the assessee was regarded as having only one residential house, so denial of the exemption had no basis. Even if the new asset at Parsvanath Exotica was transferred later, section 54F(3) affects taxation of the exempted capital gain in the year of transfer of the new asset and does not justify of the exemption in the year it was otherwise allowable. Agricultural receipts, including lease rent from agricultural land used for saplings and plantations, were also accepted as agricultural income because the assessee had supporting material and similar treatment had been accepted in earlier years and in connected precedent.
Section 54F relief was available because the Millennium Plaza property was treated as an office space and therefore a commercial property, not a residential house; the assessee was regarded as having only one residential house, so denial of the exemption had no basis. Even if the new asset at Parsvanath Exotica was transferred later, section 54F(3) affects taxation of the exempted capital gain in the year of transfer of the new asset and does not justify of the exemption in the year it was otherwise allowable. Agricultural receipts, including lease rent from agricultural land used for saplings and plantations, were also accepted as agricultural income because the assessee had supporting material and similar treatment had been accepted in earlier years and in connected precedent.
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