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 68 - genuineness of the credits - Unexplained investment by a partner - The affidavit by the partners (not on record), would only operate as a confirmation from them and, thus, only proves their identity, while, as afore-discussed, both the capacity and the genuineness are highly suspect and, therefore, rightly doubted and found as not satisfactorily explained by the Revenue. - Additions confirmed - AT
Addition u/s 68 - genuineness of the credits - Unexplained investment by a partner - The affidavit by the partners (not on record), would only operate as a confirmation from them and, thus, only proves their identity, while, as afore-discussed, both the capacity and the genuineness are highly suspect and, therefore, rightly doubted and found as not satisfactorily explained by the Revenue. - Additions confirmed - AT
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