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...
Additions u/s 56(2)(ix) - Mesne profit / liquidated damages - Amount remained with assessee after cancellation of the said sale in terms of the decree order of the Hon’ble jurisdictional Delhi High Court - the same was in the nature of mesne profit and beyond the provisions of section 56(2)(ix) - the said section is also not applicable as the twin conditions mentioned therein have not been met on the facts - AT
Additions u/s 56(2)(ix) - Mesne profit / liquidated damages - Amount remained with assessee after cancellation of the said sale in terms of the decree order of the Hon’ble jurisdictional Delhi High Court - the same was in the nature of mesne profit and beyond the provisions of section 56(2)(ix) - the said section is also not applicable as the twin conditions mentioned therein have not been met on the facts - AT
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