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...
Ratification of resignation acceptance validates separation retrospectively, while withdrawal may be refused through reasoned administrative discretio...
Redevelopment hardship compensation received as a predetermined lump-sum for shifting, re-shifting, demolition-related inconvenience and shared common areas was held to be a capital receipt, not consideration for transfer of property rights, so the addition was deleted. The first appellate authority's direction to compute capital gain on the additional 56% carpet area was treated as an enhancement of income; because no prior show-cause notice or opportunity under section 251(2) was shown, that enhancement was set aside and the issue was remitted for fresh consideration after hearing the assessee.
Redevelopment hardship compensation received as a predetermined lump-sum for shifting, re-shifting, demolition-related inconvenience and shared common areas was held to be a capital receipt, not consideration for transfer of property rights, so the addition was deleted. The first appellate authority's direction to compute capital gain on the additional 56% carpet area was treated as an enhancement of income; because no prior show-cause notice or opportunity under section 251(2) was shown, that enhancement was set aside and the issue was remitted for fresh consideration after hearing the assessee.
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