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...
WhatsApp images, standing alone, were held insufficient to sustain additions for alleged cash salary and bonus payments because they did not identify the nature of the entries, and no corroborative evidence of actual cash disbursement was produced; the additions were deleted. In the stock matter, the alleged shortage during survey failed because silo stock was not properly quantified, the verification exercise was materially deficient, and later reconciliation and supporting records were not effectively examined; the consequent addition by applying a gross profit rate on presumed unaccounted sales was also deleted. The assessee's appeals were partly allowed and the Revenue's challenge failed.
WhatsApp images, standing alone, were held insufficient to sustain additions for alleged cash salary and bonus payments because they did not identify the nature of the entries, and no corroborative evidence of actual cash disbursement was produced; the additions were deleted. In the stock matter, the alleged shortage during survey failed because silo stock was not properly quantified, the verification exercise was materially deficient, and later reconciliation and supporting records were not effectively examined; the consequent addition by applying a gross profit rate on presumed unaccounted sales was also deleted. The assessee's appeals were partly allowed and the Revenue's challenge failed.
Note: It is a system-generated summary and is for quick reference only.