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...
Bogus political donation claims under section 80GGC require the assessee to prove that the donation satisfies the statutory conditions for deduction; mere bank transfer, donation receipt, or the political party's registration is not enough. Where search material, statements, bank trail analysis and surrounding circumstances show the party acted as a conduit in an accommodation entry arrangement, authorities may apply human probabilities and the preponderance of probabilities to find the transaction -genuine, without direct proof of cash return being indispensable. Once such a cogent chain is established, the burden shifts to the assessee to rebut it with credible material. The deduction was disallowed and the appeal was dismissed.
Bogus political donation claims under section 80GGC require the assessee to prove that the donation satisfies the statutory conditions for deduction; mere bank transfer, donation receipt, or the political party's registration is not enough. Where search material, statements, bank trail analysis and surrounding circumstances show the party acted as a conduit in an accommodation entry arrangement, authorities may apply human probabilities and the preponderance of probabilities to find the transaction -genuine, without direct proof of cash return being indispensable. Once such a cogent chain is established, the burden shifts to the assessee to rebut it with credible material. The deduction was disallowed and the appeal was dismissed.
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