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...
Proper service of notice will not vitiate an appellate order unless actual prejudice is shown, and the Tribunal found no such prejudice where notices were issued through the ITBA system and multiple opportunities were granted. Rejection of books of account under section 145(3) was upheld because salary es lacked primary records, creditors remained unverified, stock discrepancies were found, and complete supporting evidence was not produced. Once the books were rejected, income estimation followed, and the Tribunal sustained the net profit rate adopted on the basis of past history, industry practice and the defects in the accounts, rejecting the challenge as unsupported.
Proper service of notice will not vitiate an appellate order unless actual prejudice is shown, and the Tribunal found no such prejudice where notices were issued through the ITBA system and multiple opportunities were granted. Rejection of books of account under section 145(3) was upheld because salary es lacked primary records, creditors remained unverified, stock discrepancies were found, and complete supporting evidence was not produced. Once the books were rejected, income estimation followed, and the Tribunal sustained the net profit rate adopted on the basis of past history, industry practice and the defects in the accounts, rejecting the challenge as unsupported.
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