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...
RTGS credits received from entities linked to an individual were treated as benami funds routed from demonetised cash, because the transfers followed demonetisation, the appellant had no prior business relationship with those entities, and the oath statement recorded under Section 131 was found admissible and relevant. The appellant's bills, ledger entries, purchase documents and stock records were not accepted as independent proof of genuine bullion sales, while the bank records corroborated receipt from unknown firms. On natural justice, the Tribunal held that no cross-examination issue arose for a person whose statement was not on record, and that no actual prejudice was shown from the failed opportunity to cross-examine the witness. The provisional attachment was sustained and the appeal dismissed.
RTGS credits received from entities linked to an individual were treated as benami funds routed from demonetised cash, because the transfers followed demonetisation, the appellant had no prior business relationship with those entities, and the oath statement recorded under Section 131 was found admissible and relevant. The appellant's bills, ledger entries, purchase documents and stock records were not accepted as independent proof of genuine bullion sales, while the bank records corroborated receipt from unknown firms. On natural justice, the Tribunal held that no cross-examination issue arose for a person whose statement was not on record, and that no actual prejudice was shown from the failed opportunity to cross-examine the witness. The provisional attachment was sustained and the appeal dismissed.
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