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 54 relief is available where capital gains are fully utilised for purchase of a new property before filing the return under section 139, even if the return is belated and no amount remains to be deposited in the Capital Gains Account Scheme. The text distinguishes cases where only unutilised amounts had to be deposited by the due date from cases where the entire consideration was already applied towards the new asset. It also records that the claim should be allowed subject to verification that the payments were made before filing the return, with the matter sent back for limited verification and consequential allowance if the utilisation is confirmed.
Section 54 relief is available where capital gains are fully utilised for purchase of a new property before filing the return under section 139, even if the return is belated and no amount remains to be deposited in the Capital Gains Account Scheme. The text distinguishes cases where only unutilised amounts had to be deposited by the due date from cases where the entire consideration was already applied towards the new asset. It also records that the claim should be allowed subject to verification that the payments were made before filing the return, with the matter sent back for limited verification and consequential allowance if the utilisation is confirmed.
Note: It is a system-generated summary and is for quick reference only.
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