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...
Receipts claimed as advances for sale of land were taxed as income from other sources because the assessee could not establish ownership, possession, or any surviving contingent right in the land, and the factual basis for treating the sums as capital receipts failed. The Tribunal held that, absent any proved property right or transfer, the amounts were taxable in the hands of the assessee. It also sustained reopening under section 147 for A.Y. 2009-10, holding that an error in the recorded quantum of receipt did not undermine the underlying reason to believe, since the MOU, the deal value, and the receipt itself remained undisputed.
Receipts claimed as advances for sale of land were taxed as income from other sources because the assessee could not establish ownership, possession, or any surviving contingent right in the land, and the factual basis for treating the sums as capital receipts failed. The Tribunal held that, absent any proved property right or transfer, the amounts were taxable in the hands of the assessee. It also sustained reopening under section 147 for A.Y. 2009-10, holding that an error in the recorded quantum of receipt did not undermine the underlying reason to believe, since the MOU, the deal value, and the receipt itself remained undisputed.
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