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...
Excess stock found during the course of survey - unexplained investments u/s 69 r.w.s.115BBE - The ITAT concluded that the addition made by the AO was not justified. They noted that the assessee had reconciled the differences in stock with supporting evidence, and neither the AO nor the CIT(A) had pointed out any defects or discrepancies in the reconciliation. - The Tribunal held that mere existence of differences in stock during a survey does not warrant automatic additions if the assessee has reconciled the differences with supporting evidence.
Excess stock found during the course of survey - unexplained investments u/s 69 r.w.s.115BBE - The ITAT concluded that the addition made by the AO was not justified. They noted that the assessee had reconciled the differences in stock with supporting evidence, and neither the AO nor the CIT(A) had pointed out any defects or discrepancies in the reconciliation. - The Tribunal held that mere existence of differences in stock during a survey does not warrant automatic additions if the assessee has reconciled the differences with supporting evidence.
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