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...
Assessee's explanation for the alleged shortfall in wastage was supported by job-work records, invoices and confirmations, and the Tribunal found no factual infirmity; the rejection of books and estimated gross profit addition were therefore deleted. In reassessment, additions for contract-payment TDS default and delayed provident fund contribution could not survive once the recorded reason for reopening itself failed in appeal, because jurisdiction to sustain unrelated additions depends on survival of the original reopening ground. A donation deduction disallowance was not decided on merits, as adverse material was not furnished and cross-examination was denied; the matter was restored for fresh adjudication after due hearing.
Assessee's explanation for the alleged shortfall in wastage was supported by job-work records, invoices and confirmations, and the Tribunal found no factual infirmity; the rejection of books and estimated gross profit addition were therefore deleted. In reassessment, additions for contract-payment TDS default and delayed provident fund contribution could not survive once the recorded reason for reopening itself failed in appeal, because jurisdiction to sustain unrelated additions depends on survival of the original reopening ground. A donation deduction disallowance was not decided on merits, as adverse material was not furnished and cross-examination was denied; the matter was restored for fresh adjudication after due hearing.
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