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...
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Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
ITAT held that investment in the new residential flat was evidenced by registered purchase documents, supported by stamp duty and registration payments, banking entries, and the vendor's confirmation of receipt through banking channels. The authorities erred in treating the investment as unexplained merely because cheques were encashed later and in doubting the lease arrangement without showing the registered deed was sham or fraudulent. The reinvestment for capital gains exemption, made within the prescribed period, was therefore allowable and the related addition under unexplained money provisions was deleted. ITAT also deleted the addition for cash deposits, accepting the cash received on sale of the original flat and the balance explained by sale of household goods and current cash balance.
ITAT held that investment in the new residential flat was evidenced by registered purchase documents, supported by stamp duty and registration payments, banking entries, and the vendor's confirmation of receipt through banking channels. The authorities erred in treating the investment as unexplained merely because cheques were encashed later and in doubting the lease arrangement without showing the registered deed was sham or fraudulent. The reinvestment for capital gains exemption, made within the prescribed period, was therefore allowable and the related addition under unexplained money provisions was deleted. ITAT also deleted the addition for cash deposits, accepting the cash received on sale of the original flat and the balance explained by sale of household goods and current cash balance.
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