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...
Non-filing of returns by some suppliers, without further enquiry or contrary material, was held insufficient to reject recorded purchases where payments were through banking channels and sales were accepted; the ad hoc gross profit addition on disputed purchases was deleted. For unaccounted sales, only the profit element was treated as taxable, and the income was estimated on a net profit basis at 2% rather than by taxing the entire sales. Alleged entry-fee receipts based on extrapolation from a limited period were curtailed, with only 25% of the estimated addition sustained. Separate addition for unexplained expenditure was deleted on telescoping, as the sustained undisclosed income was treated as available to meet that expenditure.
Non-filing of returns by some suppliers, without further enquiry or contrary material, was held insufficient to reject recorded purchases where payments were through banking channels and sales were accepted; the ad hoc gross profit addition on disputed purchases was deleted. For unaccounted sales, only the profit element was treated as taxable, and the income was estimated on a net profit basis at 2% rather than by taxing the entire sales. Alleged entry-fee receipts based on extrapolation from a limited period were curtailed, with only 25% of the estimated addition sustained. Separate addition for unexplained expenditure was deleted on telescoping, as the sustained undisclosed income was treated as available to meet that expenditure.
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