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...
Additions towards cash deposits u/s. 69A r.w.s. 115BBE in demonetized currency - Addition based on report received from the ADIT (Investigation), Trichy - The ITAT held that, no error in the findings recorded by the CIT(A) to re-compute net profit from business and to be taxable under normal rate of tax, and thus, we are inclined to uphold the findings of the CIT(A) and reject the ground taken by the Revenue.
Additions towards cash deposits u/s. 69A r.w.s. 115BBE in demonetized currency - Addition based on report received from the ADIT (Investigation), Trichy - The ITAT held that, no error in the findings recorded by the CIT(A) to re-compute net profit from business and to be taxable under normal rate of tax, and thus, we are inclined to uphold the findings of the CIT(A) and reject the ground taken by the Revenue.
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