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...
Penalty for cash receipts under section 271DA requires proof that the assessee received cash in breach of section 269ST. Where the underlying quantum addition was deleted because the alleged transaction involved other parties and not the assessee, no factual basis remained for a consequential penalty; deletion of the penalty was therefore upheld. The presumptions under sections 132(4A) and 292C apply against the person from whose possession or control seized material is found. A WhatsApp screenshot recovered from another entity's premises, without the assessee's name or admission of cash receipt, could not support a presumption against the assessee. The Revenue's appeal was dismissed.
Penalty for cash receipts under section 271DA requires proof that the assessee received cash in breach of section 269ST. Where the underlying quantum addition was deleted because the alleged transaction involved other parties and not the assessee, no factual basis remained for a consequential penalty; deletion of the penalty was therefore upheld. The presumptions under sections 132(4A) and 292C apply against the person from whose possession or control seized material is found. A WhatsApp screenshot recovered from another entity's premises, without the assessee's name or admission of cash receipt, could not support a presumption against the assessee. The Revenue's appeal was dismissed.
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