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 was construed as a beneficial provision whose substance is timely investment of capital gains in a residential house, and the Tribunal held that exemption could not be denied where that substantive requirement was met. The assessee's investment was found genuine and the discrepancy in the flat number was explained by developer records, which the Revenue did not rebut. Non-deposit of the unutilised amount in the Capital Gain Account Scheme before the due date under section 139(1) was treated as a technical lapse only, so the deduction was allowed in full and the capital gains addition was deleted.
Section 54F was construed as a beneficial provision whose substance is timely investment of capital gains in a residential house, and the Tribunal held that exemption could not be denied where that substantive requirement was met. The assessee's investment was found genuine and the discrepancy in the flat number was explained by developer records, which the Revenue did not rebut. Non-deposit of the unutilised amount in the Capital Gain Account Scheme before the due date under section 139(1) was treated as a technical lapse only, so the deduction was allowed in full and the capital gains addition was deleted.
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