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...
Unsecured loans - Additions u/s 69 as unexplained expenditure - the tribunal finds that the ld. CIT(A) rightly deleted the impugned additions as the AO failed to establish that the loss on occasion of share trading was a bogus or sham loss claimed. The second ground relates to the deletion of an addition made by the AO in respect of gross profit, and the tribunal finds that there was no difference in the amount of gross profit declared by the assessee and computed by the AO. Therefore, the tribunal dismisses the appeal of the Revenue. - AT
Unsecured loans - Additions u/s 69 as unexplained expenditure - the tribunal finds that the ld. CIT(A) rightly deleted the impugned additions as the AO failed to establish that the loss on occasion of share trading was a bogus or sham loss claimed. The second ground relates to the deletion of an addition made by the AO in respect of gross profit, and the tribunal finds that there was no difference in the amount of gross profit declared by the assessee and computed by the AO. Therefore, the tribunal dismisses the appeal of the Revenue. - AT
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