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...
Uncorroborated WhatsApp chats, incomplete promissory-note images and vague seized notings were treated as insufficient to sustain additions for undisclosed income where no cash trail, confirmations, statements or other primary evidence was produced. Proposed land and flat deals that never materialised could not support investment or on-money additions, and notional interest could not be taxed again where the same income had already been assessed elsewhere. Brokerage arising from intermediary real estate transactions was treated as business income and restricted to 2%, while telescoping of source and application was directed on verification. Jewellery found in a locker was also accepted within the prescribed household limits.
Uncorroborated WhatsApp chats, incomplete promissory-note images and vague seized notings were treated as insufficient to sustain additions for undisclosed income where no cash trail, confirmations, statements or other primary evidence was produced. Proposed land and flat deals that never materialised could not support investment or on-money additions, and notional interest could not be taxed again where the same income had already been assessed elsewhere. Brokerage arising from intermediary real estate transactions was treated as business income and restricted to 2%, while telescoping of source and application was directed on verification. Jewellery found in a locker was also accepted within the prescribed household limits.
Note: It is a system-generated summary and is for quick reference only.
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