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 u/s. 69/68 - Cash deposit in joint bank account - We are unable to comprehend as to how an addition can be made in the hands of assessee towards cash deposits in the joint bank account when not only the source of deposit but also the entire background of facts leading to the receipt of amount in the hands of assessee's wife was also thoroughly explained before the AO. The assessee's wife was separately assessed to tax, in support of which, her copies of income tax returns were also furnished. We are fully satisfied that the assessee discharged the onus upon him to prove the source of deposit in the joint bank account. - AT
Addition u/s. 69/68 - Cash deposit in joint bank account - We are unable to comprehend as to how an addition can be made in the hands of assessee towards cash deposits in the joint bank account when not only the source of deposit but also the entire background of facts leading to the receipt of amount in the hands of assessee's wife was also thoroughly explained before the AO. The assessee's wife was separately assessed to tax, in support of which, her copies of income tax returns were also furnished. We are fully satisfied that the assessee discharged the onus upon him to prove the source of deposit in the joint bank account. - AT
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