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 unexplained cash credit u/s 68 - shares were issued at premium to certain companies in lieu of the shares held by the said companies and there was thus no inflow of cash involved in these transactions - since there was no real credit of cash in the cash book and the question of inclusion of the amount of the entry as unexplained cash credit could not arise - provision of section 68 is not applicable
Addition unexplained cash credit u/s 68 - shares were issued at premium to certain companies in lieu of the shares held by the said companies and there was thus no inflow of cash involved in these transactions - since there was no real credit of cash in the cash book and the question of inclusion of the amount of the entry as unexplained cash credit could not arise - provision of section 68 is not applicable
Note: It is a system-generated summary and is for quick reference only.
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