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...
Unexplained cash deposits were sustained as additions because the assessee failed to discharge the onus of explaining their source and nature. The record showed continuing inconsistencies between the cash deposits, declared turnover, GST returns and accounting entries, and no reliable reconciliation was produced to link the deposits to alleged client reimbursements and booking advances in the travel business. In the absence of a verifiable explanation, the Tribunal found invocation of unexplained-income treatment and the consequential higher-tax regime justified, and the addition was upheld.
Unexplained cash deposits were sustained as additions because the assessee failed to discharge the onus of explaining their source and nature. The record showed continuing inconsistencies between the cash deposits, declared turnover, GST returns and accounting entries, and no reliable reconciliation was produced to link the deposits to alleged client reimbursements and booking advances in the travel business. In the absence of a verifiable explanation, the Tribunal found invocation of unexplained-income treatment and the consequential higher-tax regime justified, and the addition was upheld.
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