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...
Undisclosed income of capital gain - cost of acquisition - It is an admitted fact that on 28.03.2016, the Ld. AO received the valuation report submitted by the appellant, much after the valuation report dated 15/16-03-2016 as obtained by the Ld. AO from the DVO . In spite of the several opportunities, no objection was filed in regard to the same by the appellant neither any evidence has been relied upon even during the appellate proceeding. - Additions confirmed - AT
Undisclosed income of capital gain - cost of acquisition - It is an admitted fact that on 28.03.2016, the Ld. AO received the valuation report submitted by the appellant, much after the valuation report dated 15/16-03-2016 as obtained by the Ld. AO from the DVO . In spite of the several opportunities, no objection was filed in regard to the same by the appellant neither any evidence has been relied upon even during the appellate proceeding. - Additions confirmed - AT
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