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 56(2)(x) applies to any immovable property, so agricultural land purchased by the assessee was not from its scope merely because it was not a capital asset. The Tribunal held that the capital-asset character of agricultural land is relevant for the seller's capital gains computation, not for the buyer's liability under this provision, and therefore the addition was justified. It also found that the assessee had sought adoption of the DVO valuation instead of the higher stamp duty value and could not later challenge that very report or demand a fresh valuation exercise. The appeal was dismissed and the addition sustained.
Section 56(2)(x) applies to any immovable property, so agricultural land purchased by the assessee was not from its scope merely because it was not a capital asset. The Tribunal held that the capital-asset character of agricultural land is relevant for the seller's capital gains computation, not for the buyer's liability under this provision, and therefore the addition was justified. It also found that the assessee had sought adoption of the DVO valuation instead of the higher stamp duty value and could not later challenge that very report or demand a fresh valuation exercise. The appeal was dismissed and the addition sustained.
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