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 u/s 68 - Applicability of higher rate of tax u/s 115BBE - Sourcing unsecured loan against Cash Deposit - the assessee has failed to explain the source of cash deposit to her bank account - The amount remained unexplained and the AO was right in making the addition - Addition made u/s. 68 with higher rate u/s. 115BBE - AT
Addition u/s 68 - Applicability of higher rate of tax u/s 115BBE - Sourcing unsecured loan against Cash Deposit - the assessee has failed to explain the source of cash deposit to her bank account - The amount remained unexplained and the AO was right in making the addition - Addition made u/s. 68 with higher rate u/s. 115BBE - AT
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