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...
Validity of Reopening of assessment - disallowance of expenditure being the inflated cost of fuels - information from the Directorate of Revenue Intelligence (DRI) relied upon - The Tribunal noted that, the basis for the reopening, a DRI show cause notice, was quashed by the competent authority/ CESTAT, making the reassessment unsustainable. The ITAT upheld the order of CIT(A) deleting the additions as the determination made by the AO in any case is un-sustainable being sans foundation/substantive material.
Validity of Reopening of assessment - disallowance of expenditure being the inflated cost of fuels - information from the Directorate of Revenue Intelligence (DRI) relied upon - The Tribunal noted that, the basis for the reopening, a DRI show cause notice, was quashed by the competent authority/ CESTAT, making the reassessment unsustainable. The ITAT upheld the order of CIT(A) deleting the additions as the determination made by the AO in any case is un-sustainable being sans foundation/substantive material.
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