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 held available where sale consideration was invested in a residential house before filing the return under section 139(4), so deposit in the capital gains account was not required. The Tribunal also held that an undivided one-third share in a single contiguous residential property did not amount to ownership of two separate houses, so the assessee was not disentitled on that ground. It further ruled that section 54F must be applied asset-wise: shares of each company were separate capital assets, and long-term capital loss could not be used to deny exemption on gains from other assets.
Section 54F relief was held available where sale consideration was invested in a residential house before filing the return under section 139(4), so deposit in the capital gains account was not required. The Tribunal also held that an undivided one-third share in a single contiguous residential property did not amount to ownership of two separate houses, so the assessee was not disentitled on that ground. It further ruled that section 54F must be applied asset-wise: shares of each company were separate capital assets, and long-term capital loss could not be used to deny exemption on gains from other assets.
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