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...
Addition of undisclosed income u/s 69B - purchase of share from its directors and their closely held companies - nothing on record would demonstrate any exchange / flow of funds, out of books, between the assessee and the sellers - in the absence of any evidences establishing receipts & payments outside regular books of accounts, the provisions of Section 69B could not be invoked - addition deleted
Addition of undisclosed income u/s 69B - purchase of share from its directors and their closely held companies - nothing on record would demonstrate any exchange / flow of funds, out of books, between the assessee and the sellers - in the absence of any evidences establishing receipts & payments outside regular books of accounts, the provisions of Section 69B could not be invoked - addition deleted
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