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 - We do not understand proposition of the assessee that cash had changed the hands from the company to its promoter–Director without any reason and there is no reason forthcoming as to why the cash was paid in cash by the three parties. There is no document produced before either the AO or before CIT (Appeals) or before us to prove the genuineness of the transaction. - While deleting the addition the CIT (Appeals) has not discussed about the proving of genuineness of the transaction by the assessee. - Matter restored back - AT
Addition u/s 68 - We do not understand proposition of the assessee that cash had changed the hands from the company to its promoter–Director without any reason and there is no reason forthcoming as to why the cash was paid in cash by the three parties. There is no document produced before either the AO or before CIT (Appeals) or before us to prove the genuineness of the transaction. - While deleting the addition the CIT (Appeals) has not discussed about the proving of genuineness of the transaction by the assessee. - Matter restored back - AT
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