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...
ITAT notes that unaccounted sales should be taxed only to the extent of net profit embedded in those sales where seized material reflects both direct costs and indirect expenses; taxing the full gross profit element is excessive, and the rate in this matter was fixed at 2%. It also states that cash found during search can be telescoped against income already sustained on estimate where no separate use of that income elsewhere is shown, so a separate unexplained-money addition is deleted. Further, where profit estimation already subsumes the expenditure of the unaccounted activity, a separate addition for unexplained expenditure under section 69C would amount to double addition and should not survive.
ITAT notes that unaccounted sales should be taxed only to the extent of net profit embedded in those sales where seized material reflects both direct costs and indirect expenses; taxing the full gross profit element is excessive, and the rate in this matter was fixed at 2%. It also states that cash found during search can be telescoped against income already sustained on estimate where no separate use of that income elsewhere is shown, so a separate unexplained-money addition is deleted. Further, where profit estimation already subsumes the expenditure of the unaccounted activity, a separate addition for unexplained expenditure under section 69C would amount to double addition and should not survive.
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