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...
Assessment u/s 153A - undisclosed income - purchase of properties - payment of on money - AO has rejected the reply to the show cause notice without assigning proper reasons by merely relying on the estimation without any justification. - AO has not given any break-up of the income by deducting the bund area and also the income from Fish Culture with respect to the leased lands. - the assessee has offered an amount of Rs. 74,458/-per Acre (net of Bund area), and which is more than the rate per Acre fixed by the jurisdictional Bench - CIT(A) rightly deleted the additions - AT
Assessment u/s 153A - undisclosed income - purchase of properties - payment of on money - AO has rejected the reply to the show cause notice without assigning proper reasons by merely relying on the estimation without any justification. - AO has not given any break-up of the income by deducting the bund area and also the income from Fish Culture with respect to the leased lands. - the assessee has offered an amount of Rs. 74,458/-per Acre (net of Bund area), and which is more than the rate per Acre fixed by the jurisdictional Bench - CIT(A) rightly deleted the additions - AT
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