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 43CA(3) permits adoption of the stamp duty value on the agreement date where the agreement and registration dates differ, provided consideration or part thereof was received through prescribed banking or electronic modes on or before the agreement date. The Tribunal found the assessee's documents, including allotment letters, registered sale agreements, possession letters, completion-related records and financial statements, had not been properly examined, and held that the 10% safe harbour claim also required verification. The sustained addition was therefore set aside and the matter remanded to the AO for fresh adjudication after examining the evidence and giving the assessee an opportunity of hearing.
Section 43CA(3) permits adoption of the stamp duty value on the agreement date where the agreement and registration dates differ, provided consideration or part thereof was received through prescribed banking or electronic modes on or before the agreement date. The Tribunal found the assessee's documents, including allotment letters, registered sale agreements, possession letters, completion-related records and financial statements, had not been properly examined, and held that the 10% safe harbour claim also required verification. The sustained addition was therefore set aside and the matter remanded to the AO for fresh adjudication after examining the evidence and giving the assessee an opportunity of hearing.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4814 
Join Channel 
