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...
A typographical error in the appellate directions led the Assessing Officer to retain part of a section 69 addition for unexplained investment, even though the draft assessment order had made a combined addition for time deposits and reportable transactions. The Tribunal read the reasoning in the directions as showing that both underlying components were meant to be deleted, and treated the differing aggregate figure as a clerical mistake. On that basis, no balance addition could survive in the final assessment order, and the retained amount was deleted.
A typographical error in the appellate directions led the Assessing Officer to retain part of a section 69 addition for unexplained investment, even though the draft assessment order had made a combined addition for time deposits and reportable transactions. The Tribunal read the reasoning in the directions as showing that both underlying components were meant to be deleted, and treated the differing aggregate figure as a clerical mistake. On that basis, no balance addition could survive in the final assessment order, and the retained amount was deleted.
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