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...
Capital gains for AY 2016-17 had to be recomputed by correcting an assessment-year mismatch, excluding a property transfer recorded in the succeeding year and including the deed relating to the year under consideration. The Tribunal also treated one sale entry as a duplicate because the later document merely rectified an error in the earlier deed, so only the corrected transaction could be counted. For the co-owned property sale, where the deed did not specify separate shares, the assessee's taxable share was restricted to one-fifth of the total consideration. The assessment was revised accordingly.
Capital gains for AY 2016-17 had to be recomputed by correcting an assessment-year mismatch, excluding a property transfer recorded in the succeeding year and including the deed relating to the year under consideration. The Tribunal also treated one sale entry as a duplicate because the later document merely rectified an error in the earlier deed, so only the corrected transaction could be counted. For the co-owned property sale, where the deed did not specify separate shares, the assessee's taxable share was restricted to one-fifth of the total consideration. The assessment was revised accordingly.
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