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...
Telescoping of commission income already offered was confined to the net income returned and not to the gross profit claimed, where the assessee's business transactions were found to be bogus and commission income was to be estimated on the reported turnover and fresh investments. The recomputation was directed on that basis after reducing the income already declared. Cash deposits during the demonetisation period were held explained by earlier cash withdrawals, supported by date-wise details, bank statements and books of account, so the unexplained-money addition was deleted. Self-assessment tax credit reflected in Form 26AS was directed to be allowed after verification by the AO.
Telescoping of commission income already offered was confined to the net income returned and not to the gross profit claimed, where the assessee's business transactions were found to be bogus and commission income was to be estimated on the reported turnover and fresh investments. The recomputation was directed on that basis after reducing the income already declared. Cash deposits during the demonetisation period were held explained by earlier cash withdrawals, supported by date-wise details, bank statements and books of account, so the unexplained-money addition was deleted. Self-assessment tax credit reflected in Form 26AS was directed to be allowed after verification by the AO.
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