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 set aside the disallowance of agricultural income exemption for AY 2016-17 after finding that supporting bills and invoices had been filed but not considered, while land ownership and agricultural use evidence remained incomplete; the matter was remanded for fresh adjudication with opportunity to file further material. The deletion of the addition under section 69 for unexplained investment in immovable properties was also vacated because the appellate relief had been based on additional evidence not properly dealt with, and the applicability of section 69 was left open for the Assessing Officer. For AY 2020-21, the denial of agricultural income exemption was remanded because relied-upon adverse material was not clearly confronted to the assessee, requiring fresh decision after hearing.
ITAT set aside the disallowance of agricultural income exemption for AY 2016-17 after finding that supporting bills and invoices had been filed but not considered, while land ownership and agricultural use evidence remained incomplete; the matter was remanded for fresh adjudication with opportunity to file further material. The deletion of the addition under section 69 for unexplained investment in immovable properties was also vacated because the appellate relief had been based on additional evidence not properly dealt with, and the applicability of section 69 was left open for the Assessing Officer. For AY 2020-21, the denial of agricultural income exemption was remanded because relied-upon adverse material was not clearly confronted to the assessee, requiring fresh decision after hearing.
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