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 difference of the gross receipts shown in the 26AS in comparison to the ITR - Once the assessee has disputed the said amount pertaining to any of the bills raised by the assessee, then a proper enquiry ought to have been conducted by the AO to verify this fact. The assessee has expressed its inability to force the other party to rectify the TDS statement and consequently 26AS - we set aside this issue to the record of the AO for conducting a proper enquiry - AT
Addition on account of difference of the gross receipts shown in the 26AS in comparison to the ITR - Once the assessee has disputed the said amount pertaining to any of the bills raised by the assessee, then a proper enquiry ought to have been conducted by the AO to verify this fact. The assessee has expressed its inability to force the other party to rectify the TDS statement and consequently 26AS - we set aside this issue to the record of the AO for conducting a proper enquiry - AT
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