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...
Ad hoc confirmation of one-fifth of an alleged unexplained investment in a flat was found arbitrary where the source of payments was supported by bank transfers, housing finance, accumulated savings from government service, family agricultural income, and the spouse's income; that addition was deleted. The separate addition for the difference between stamp duty value and purchase price was also deleted because the order gave no cogent reason for refusing a valuation reference, relied on the wrong charging provision for the relevant assessment year, and ignored evidence showing demolition action for unauthorised construction, which supported the declared price as the flat's fair market value.
Ad hoc confirmation of one-fifth of an alleged unexplained investment in a flat was found arbitrary where the source of payments was supported by bank transfers, housing finance, accumulated savings from government service, family agricultural income, and the spouse's income; that addition was deleted. The separate addition for the difference between stamp duty value and purchase price was also deleted because the order gave no cogent reason for refusing a valuation reference, relied on the wrong charging provision for the relevant assessment year, and ignored evidence showing demolition action for unauthorised construction, which supported the declared price as the flat's fair market value.
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