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...
An addition for unexplained investment cannot be sustained unless the investment was made in the financial year immediately preceding the relevant assessment year. Here, the ledger accounts and year-wise expenditure charts showed that the opening work-in-progress consisted of expenditure incurred over several earlier years, and the Revenue itself treated it as a prior-period balance. The Assessing Officer could not tax that historical investment in the current year merely because earlier returns were filed on a non-business basis or because prior disclosure was allegedly incomplete. The addition under Section 69 was therefore unsustainable and was deleted.
An addition for unexplained investment cannot be sustained unless the investment was made in the financial year immediately preceding the relevant assessment year. Here, the ledger accounts and year-wise expenditure charts showed that the opening work-in-progress consisted of expenditure incurred over several earlier years, and the Revenue itself treated it as a prior-period balance. The Assessing Officer could not tax that historical investment in the current year merely because earlier returns were filed on a non-business basis or because prior disclosure was allegedly incomplete. The addition under Section 69 was therefore unsustainable and was deleted.
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