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...
ITAT held that cash deposits in a small trader's bank account, including interest, could not again be assessed as unexplained income where they arose from retail trading receipts and profit had already been offered on those receipts. Accepting that the assessee dealt in agricultural produce and had disclosed presumptive profit at 5% on business turnover, the Tribunal applied the principle that once bank deposits are treated as turnover and taxed through estimated profit, the entire deposits cannot be added again. The addition made by the lower authority was deleted.
ITAT held that cash deposits in a small trader's bank account, including interest, could not again be assessed as unexplained income where they arose from retail trading receipts and profit had already been offered on those receipts. Accepting that the assessee dealt in agricultural produce and had disclosed presumptive profit at 5% on business turnover, the Tribunal applied the principle that once bank deposits are treated as turnover and taxed through estimated profit, the entire deposits cannot be added again. The addition made by the lower authority was deleted.
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