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...
On identical facts, the ITAT applied the principle of consistency and upheld assessment of only 1% commission on gross bank transactions, rejecting a broader addition. The Tribunal noted that in the preceding year the Assessing Officer had treated the assessee as a consignment sales agent for Khal Binola and taxed only commission income, and that tax deduction under section 194H supported the view that the bank deposits represented consignment sale proceeds on behalf of principals. Following Radhasoami Satsang and Excel Industries, the Tribunal sustained the addition only to that limited extent and deleted the balance.
On identical facts, the ITAT applied the principle of consistency and upheld assessment of only 1% commission on gross bank transactions, rejecting a broader addition. The Tribunal noted that in the preceding year the Assessing Officer had treated the assessee as a consignment sales agent for Khal Binola and taxed only commission income, and that tax deduction under section 194H supported the view that the bank deposits represented consignment sale proceeds on behalf of principals. Following Radhasoami Satsang and Excel Industries, the Tribunal sustained the addition only to that limited extent and deleted the balance.
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