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 made towards excess physical stock during the survey - unexplained investment u/s 69 taxable at rates prescribed u/s 115BBE - The ITAT concurred with the Commissioner's decision, stating that the Assessing Officer failed to rebut the assessee's valuation adjustments adequately. They agreed that the discrepancy in stock could be attributed to unrecorded sales, and upheld the Commissioner's decision to treat the addition as business income. - The ITAT dismissed the Revenue's appeal, affirming the Commissioner's order deleting the additions.
Addition made towards excess physical stock during the survey - unexplained investment u/s 69 taxable at rates prescribed u/s 115BBE - The ITAT concurred with the Commissioner's decision, stating that the Assessing Officer failed to rebut the assessee's valuation adjustments adequately. They agreed that the discrepancy in stock could be attributed to unrecorded sales, and upheld the Commissioner's decision to treat the addition as business income. - The ITAT dismissed the Revenue's appeal, affirming the Commissioner's order deleting the additions.
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