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 mismatch in the interest amount with form 26AS - The transaction shown in form 26AS cannot be taken as the gospel truth that it represents the income in the hands of the assessee especially in a situation where the assessee has contended that the above amount representing was reimbursement of the expenses. In such a situation, the Revenue is expected to be more vigilant before reaching to the conclusion that the assessee has not shown certain income. - AT
Addition on account of mismatch in the interest amount with form 26AS - The transaction shown in form 26AS cannot be taken as the gospel truth that it represents the income in the hands of the assessee especially in a situation where the assessee has contended that the above amount representing was reimbursement of the expenses. In such a situation, the Revenue is expected to be more vigilant before reaching to the conclusion that the assessee has not shown certain income. - AT
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