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...
Income Disclosure Scheme, 2016 immunity protected declared...
Income Disclosure Scheme immunity and search-material requirements barred further share-transaction additions in unabated assessments under section 153A.
Contents
Summary
Note
Bookmark
Share
✓ Copied successfully !
Print
Print Options
For full text, please login
Login to TaxTMI
Verification Pending
The Email Id has not been verified. Click on the link we have sent on
Income Disclosure Scheme, 2016 immunity protected declared long-term capital gains from further taxation where the taxpayer had disclosed the share-sale gains and paid the prescribed tax. ITAT therefore upheld deletion of the addition for differential share-sale proceeds under section 68. For unabated assessments under section 153A, additions require incriminating material found during the search of the taxpayer. Third-party investigation material and statements recorded in other proceedings did not satisfy that requirement. ITAT sustained deletion of additions relating to alleged bogus capital gains and short-term capital loss, dismissed the Department's appeals, and dismissed unpressed cross-objections.
Income Disclosure Scheme, 2016 immunity protected declared long-term capital gains from further taxation where the taxpayer had disclosed the share-sale gains and paid the prescribed tax. ITAT therefore upheld deletion of the addition for differential share-sale proceeds under section 68. For unabated assessments under section 153A, additions require incriminating material found during the search of the taxpayer. Third-party investigation material and statements recorded in other proceedings did not satisfy that requirement. ITAT sustained deletion of additions relating to alleged bogus capital gains and short-term capital loss, dismissed the Department's appeals, and dismissed unpressed cross-objections.
Note: It is a system-generated summary and is for quick reference only.