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 on account of excess stock - discrepancies in stock records, unaccounted sales - we are satisfied with the documentary evidence that the alleged stock of cotton bales were part of book stock and they were issued out of stock on 24.1.2012 and were sold through the invoices issued on 25.1.2012. Physical stock was taken by the revenue authorities on the date of survey on 24.1.2002 - Addition deleted.- AT
Addition on account of excess stock - discrepancies in stock records, unaccounted sales - we are satisfied with the documentary evidence that the alleged stock of cotton bales were part of book stock and they were issued out of stock on 24.1.2012 and were sold through the invoices issued on 25.1.2012. Physical stock was taken by the revenue authorities on the date of survey on 24.1.2002 - Addition deleted.- AT
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