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...
ITAT held that deduction under section 54 could not be denied on technical or documentary objections where the record showed substantial investment in construction of a residential house and utilisation of capital gains for that purpose. It accepted the Joint Development Agreement and expenditure evidence as sufficient, noting no specific defect or adverse finding on genuineness, and applied a liberal construction to this beneficial exemption provision. The disallowance was deleted. On Chapter VI-A claims under sections 80C and 80D, the Tribunal upheld the direction to verify the supporting documents and allow the admissible deduction in accordance with law.
ITAT held that deduction under section 54 could not be denied on technical or documentary objections where the record showed substantial investment in construction of a residential house and utilisation of capital gains for that purpose. It accepted the Joint Development Agreement and expenditure evidence as sufficient, noting no specific defect or adverse finding on genuineness, and applied a liberal construction to this beneficial exemption provision. The disallowance was deleted. On Chapter VI-A claims under sections 80C and 80D, the Tribunal upheld the direction to verify the supporting documents and allow the admissible deduction in accordance with law.
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