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...
Rejection of books of accounts u/s 145 (3) - AO by recklessly rejecting the books of account proceeded to estimate the income by applying profit @ 5% of the gross receipt which much less than the income for which the assessee company has already assessed (before depreciation). - CIT (A) has rightly and validly accepted the books of account and set aside the estimation of gross profit @ 5% - AT
Rejection of books of accounts u/s 145 (3) - AO by recklessly rejecting the books of account proceeded to estimate the income by applying profit @ 5% of the gross receipt which much less than the income for which the assessee company has already assessed (before depreciation). - CIT (A) has rightly and validly accepted the books of account and set aside the estimation of gross profit @ 5% - AT
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