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...
Benami property determination was set aside where the adjudicating authority relied on recovered documents, statements, surrounding circumstances and unaccounted cash material, yet reached internally inconsistent findings on whether the alleged beneficial owner's funding was proved while still declaring the property benami and the appellant a benamidar. The Tribunal noted that the appellant's later ownership claim contradicted his earlier statements and affidavit, but also found that the full evidentiary record had not been properly considered. The matter was remanded for fresh consideration on all facts, statements, affidavits and investigative material, with status quo on the property maintained.
Benami property determination was set aside where the adjudicating authority relied on recovered documents, statements, surrounding circumstances and unaccounted cash material, yet reached internally inconsistent findings on whether the alleged beneficial owner's funding was proved while still declaring the property benami and the appellant a benamidar. The Tribunal noted that the appellant's later ownership claim contradicted his earlier statements and affidavit, but also found that the full evidentiary record had not been properly considered. The matter was remanded for fresh consideration on all facts, statements, affidavits and investigative material, with status quo on the property maintained.
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