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 deposits during demonetisation were accepted as explained where recorded sales, stock details, VAT returns and cash-in-hand records supported the books; the estimated gross profit addition failed because the books were rejected without specific defects, and the material showed stock-backed sales rather than suspicion. The Tribunal also held that M/s. Jain Bullion belonged to its proprietor, not the assessee, since the relevant bank accounts were operated by the proprietor and the concern had separately conducted business and filed returns. Separately, the notional annual letting value addition in search assessment was deleted because no incriminating material for that item was found during the search.
Cash deposits during demonetisation were accepted as explained where recorded sales, stock details, VAT returns and cash-in-hand records supported the books; the estimated gross profit addition failed because the books were rejected without specific defects, and the material showed stock-backed sales rather than suspicion. The Tribunal also held that M/s. Jain Bullion belonged to its proprietor, not the assessee, since the relevant bank accounts were operated by the proprietor and the concern had separately conducted business and filed returns. Separately, the notional annual letting value addition in search assessment was deleted because no incriminating material for that item was found during the search.
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