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...
Reassessment initiated on a mistaken factual premise and without a live nexus to incriminating material was held unsustainable, as the record did not link the assessee to the seized third-party material and the jurisdictional approval objection was unrebutted. The Tribunal also found that approval under the reassessment provisions had not been shown to be validly obtained and that the sanction was mechanical, so the reassessment order was quashed. On the alleged on-money addition, unexplained reliance on un-confronted Excel entries and third-party statements could not displace the assessee's banking records and other documents, and the section 69 addition was deleted.
Reassessment initiated on a mistaken factual premise and without a live nexus to incriminating material was held unsustainable, as the record did not link the assessee to the seized third-party material and the jurisdictional approval objection was unrebutted. The Tribunal also found that approval under the reassessment provisions had not been shown to be validly obtained and that the sanction was mechanical, so the reassessment order was quashed. On the alleged on-money addition, unexplained reliance on un-confronted Excel entries and third-party statements could not displace the assessee's banking records and other documents, and the section 69 addition was deleted.
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