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...
Penny-stock share sale proceeds cannot be treated as unexplained money merely on suspicion of accommodation entries where purchases and sales occurred through banking channels, demat accounts and the stock exchange. Investigation findings about broker manipulation require material linking the taxpayer to bogus purchases, cash exchanges, price rigging or an entry arrangement; absent such evidence, documentary transaction records prevail and the addition is unsustainable. Exempt long-term capital gains nevertheless require disclosure through a return, and failure to file a return for the relevant year can justify reassessment proceedings.
Penny-stock share sale proceeds cannot be treated as unexplained money merely on suspicion of accommodation entries where purchases and sales occurred through banking channels, demat accounts and the stock exchange. Investigation findings about broker manipulation require material linking the taxpayer to bogus purchases, cash exchanges, price rigging or an entry arrangement; absent such evidence, documentary transaction records prevail and the addition is unsustainable. Exempt long-term capital gains nevertheless require disclosure through a return, and failure to file a return for the relevant year can justify reassessment proceedings.
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