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...
Assessments made under limited scrutiny cannot travel beyond the subject identified in the notice; where the notice was confined to cash deposits, additions on the capital gains exemption claim and treatment of income as business income were invalid. A revised return, once validly filed, replaces the original return; where the Assessing Officer framed the assessment on the basis of the original return while ignoring the revised return, that assessment could not be sustained. The impugned addition was deleted and the appeal was allowed.
Assessments made under limited scrutiny cannot travel beyond the subject identified in the notice; where the notice was confined to cash deposits, additions on the capital gains exemption claim and treatment of income as business income were invalid. A revised return, once validly filed, replaces the original return; where the Assessing Officer framed the assessment on the basis of the original return while ignoring the revised return, that assessment could not be sustained. The impugned addition was deleted and the appeal was allowed.
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