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...
Bogus loans u/s 68 - unsecured loans from the three loan creditors and interest on loans - reliance on third party statement - The ITAT upheld the CIT(A)'s order, stating that the assessee had discharged its burden by submitting the requisite information, and the onus lies on the AO to make enquiries. The AO failed to make further enquiries and relied on the statement recorded, which was retracted subsequently. - AT
Bogus loans u/s 68 - unsecured loans from the three loan creditors and interest on loans - reliance on third party statement - The ITAT upheld the CIT(A)'s order, stating that the assessee had discharged its burden by submitting the requisite information, and the onus lies on the AO to make enquiries. The AO failed to make further enquiries and relied on the statement recorded, which was retracted subsequently. - AT
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