Pure-agent exclusion fails where hotel booking facilitators receive third-party services themselves, making entire customer consideration taxable as r...
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...
Addition u/s 68 - loans from relatives through banking channel - it is also not in dispute that cash deposits were made in the bank account of the creditor just before advancing the loan and no explanation was forthcoming before the authorities below - the onus of proving the source of a sum of money found to have been received by the assessee is on him and if he disputes the liability for tax - addition sustained
Addition u/s 68 - loans from relatives through banking channel - it is also not in dispute that cash deposits were made in the bank account of the creditor just before advancing the loan and no explanation was forthcoming before the authorities below - the onus of proving the source of a sum of money found to have been received by the assessee is on him and if he disputes the liability for tax - addition sustained
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