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...
Unexplained cash deposits in Bank account and undisclosed interest income - The Gift from wife was also explained by the assessee through bank statements. Regarding personal saving the CIT(A) doubted that the assessee could not save that much amount. But the assessee was working as pharmacist in Government Hospital since 1976 and received salary, therefore, personal saving of a government employee cannot be doubted for several years. - AT
Unexplained cash deposits in Bank account and undisclosed interest income - The Gift from wife was also explained by the assessee through bank statements. Regarding personal saving the CIT(A) doubted that the assessee could not save that much amount. But the assessee was working as pharmacist in Government Hospital since 1976 and received salary, therefore, personal saving of a government employee cannot be doubted for several years. - AT
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