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 belated challenge to the Assessing Officer's jurisdiction failed because no objection was raised during assessment or before completion of the assessment, and the point was first taken only as an additional ground; the tribunal therefore treated the objection as barred by the statutory time limit. The addition for unexplained money was also sustained because the cash book did not evidence availability of cash on the date of seizure, with no entries for the intervening period and no support for the claim that the cash belonged to the firm or had been withdrawn for purchases. The appeal was dismissed.
A belated challenge to the Assessing Officer's jurisdiction failed because no objection was raised during assessment or before completion of the assessment, and the point was first taken only as an additional ground; the tribunal therefore treated the objection as barred by the statutory time limit. The addition for unexplained money was also sustained because the cash book did not evidence availability of cash on the date of seizure, with no entries for the intervening period and no support for the claim that the cash belonged to the firm or had been withdrawn for purchases. The appeal was dismissed.
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