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...
Undisclosed unaccounted expenditure and undisclosed income - By the connotation of "right person", it is meant the person who is liable to be taxed, according to law, with respect to a particular income. And that the expression "wrong person" is obviously used as an antithesis of the expression "right person" only. - We observe that this assessee is the "managing director" in the company. - And that it is this latter entity which the fact is engaged in all the business activity(ies) and has been assessed separately throughout. A company is very a body corporate and a distinct entity apart from its director. - CIT(A) has rightly deleted these twin additions in the assessee/individual's hands - AT
Undisclosed unaccounted expenditure and undisclosed income - By the connotation of "right person", it is meant the person who is liable to be taxed, according to law, with respect to a particular income. And that the expression "wrong person" is obviously used as an antithesis of the expression "right person" only. - We observe that this assessee is the "managing director" in the company. - And that it is this latter entity which the fact is engaged in all the business activity(ies) and has been assessed separately throughout. A company is very a body corporate and a distinct entity apart from its director. - CIT(A) has rightly deleted these twin additions in the assessee/individual's hands - AT
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