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...
Additional documentary evidence on the GST refund mismatch was admitted as vital to verifying its accounting and tax treatment. Because the evidence required verification by the Assessing Officer and the Revenue did not oppose admission, the adjustment reducing the returned business loss was set aside and remanded for fresh adjudication after a hearing. Outstanding trade payables arising from purchases could not be treated as unexplained cash credit where creditor-balance differences had been reconciled and supported by documentary evidence. In the absence of contrary material or precedent from the Revenue, deletion of that addition was upheld and the Revenue's appeal was dismissed.
Additional documentary evidence on the GST refund mismatch was admitted as vital to verifying its accounting and tax treatment. Because the evidence required verification by the Assessing Officer and the Revenue did not oppose admission, the adjustment reducing the returned business loss was set aside and remanded for fresh adjudication after a hearing. Outstanding trade payables arising from purchases could not be treated as unexplained cash credit where creditor-balance differences had been reconciled and supported by documentary evidence. In the absence of contrary material or precedent from the Revenue, deletion of that addition was upheld and the Revenue's appeal was dismissed.
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