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...
Revision for inadequate inquiry under section 263 requires a showing that the Assessing Officer's inquiry was inadequate; a different revisional view alone does not satisfy Explanation 2(a). Reassessment initiated on specific information about alleged penny-stock share transactions involved queries and consideration of contract notes, brokerage and ledger records, and bank statements. Acceptance of short-term capital gains as genuine was therefore a plausible view. The reassessment order was not erroneous or prejudicial to Revenue interests, the revision was annulled, and the proposed-addition challenge became infructuous.
Revision for inadequate inquiry under section 263 requires a showing that the Assessing Officer's inquiry was inadequate; a different revisional view alone does not satisfy Explanation 2(a). Reassessment initiated on specific information about alleged penny-stock share transactions involved queries and consideration of contract notes, brokerage and ledger records, and bank statements. Acceptance of short-term capital gains as genuine was therefore a plausible view. The reassessment order was not erroneous or prejudicial to Revenue interests, the revision was annulled, and the proposed-addition challenge became infructuous.
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