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...
Cash credit - Additions u/s 68 instead of u/s 69 - Mentioning of wrong Section in the orders of the authorities below would not be fatal to the case of Revenue. May be technically Section 68 is not applicable in the case of the assessee, but, assessee failed to explain source of the cash deposit in her bank account - additions confirmed - AT
Cash credit - Additions u/s 68 instead of u/s 69 - Mentioning of wrong Section in the orders of the authorities below would not be fatal to the case of Revenue. May be technically Section 68 is not applicable in the case of the assessee, but, assessee failed to explain source of the cash deposit in her bank account - additions confirmed - AT
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