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...
Reopening of assessment u/s 147 - Income from other sources or business income - The impugned reopening itself is not sustainable in the light of the alleged twin reasons recorded by the Assessing Officer which have been decided in the tribunal first round that the same did not give rise to any taxable income which could be stated to have escaped assessment in assessee's case. It is thus apparent that the impugned additions be it as income from 'other' sources or 'business', both are contrary to the tribunal's remand directions closing all options of assessing the entire credit, debit as well as estimates thereof would not help the Revenue's cause. - AT
Reopening of assessment u/s 147 - Income from other sources or business income - The impugned reopening itself is not sustainable in the light of the alleged twin reasons recorded by the Assessing Officer which have been decided in the tribunal first round that the same did not give rise to any taxable income which could be stated to have escaped assessment in assessee's case. It is thus apparent that the impugned additions be it as income from 'other' sources or 'business', both are contrary to the tribunal's remand directions closing all options of assessing the entire credit, debit as well as estimates thereof would not help the Revenue's cause. - AT
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