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...
Cash receipts and repayments between an assessee and close family members, including related family entities, were not treated as loans or deposits under the relevant cash transaction provisions. The Tribunal noted that the family relationship was undisputed and applied the Gujarat High Court ratio in Dr. Rajaram L. Akhani to hold that such intra-family transactions do not fall within the mischief of the cash loan and deposit restrictions. As the statutory foundation for penalty failed, the penalties for cash acceptance and cash repayment were unsustainable and were deleted; both appeals were allowed.
Cash receipts and repayments between an assessee and close family members, including related family entities, were not treated as loans or deposits under the relevant cash transaction provisions. The Tribunal noted that the family relationship was undisputed and applied the Gujarat High Court ratio in Dr. Rajaram L. Akhani to hold that such intra-family transactions do not fall within the mischief of the cash loan and deposit restrictions. As the statutory foundation for penalty failed, the penalties for cash acceptance and cash repayment were unsustainable and were deleted; both appeals were allowed.
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