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...
A scrutiny assessment challenge based on alleged non-compliance with CBDT scrutiny-selection instructions was rejected, the Tribunal following binding jurisdictional High Court precedent. The rent-related disallowance under section 40(a)(ia) was deleted to the extent tax was not deductible, including rent paid to Haryana Urban Development Authority. In the bogus purchase dispute, the Tribunal upheld partial relief and gross profit estimation at 2.37% on market-comparable reasoning, and applied the same approach to the connected unexplained expenditure issue. The estimated addition on sundry creditors was rejected because no individual credit entries were examined and the purchases stood accepted. The related-party salary disallowance under section 40A(2)(b) was also upheld as deleted on revenue-neutrality grounds.
A scrutiny assessment challenge based on alleged non-compliance with CBDT scrutiny-selection instructions was rejected, the Tribunal following binding jurisdictional High Court precedent. The rent-related disallowance under section 40(a)(ia) was deleted to the extent tax was not deductible, including rent paid to Haryana Urban Development Authority. In the bogus purchase dispute, the Tribunal upheld partial relief and gross profit estimation at 2.37% on market-comparable reasoning, and applied the same approach to the connected unexplained expenditure issue. The estimated addition on sundry creditors was rejected because no individual credit entries were examined and the purchases stood accepted. The related-party salary disallowance under section 40A(2)(b) was also upheld as deleted on revenue-neutrality grounds.
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