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...
Revision u/s 263 - unexplained cash deposits - The tribunal rejected the notion that unexplained deposits prior to withdrawals undermined the explanation provided by the appellant. - Regarding the PCIT's assertion of the AO's mistake in not making the addition, the tribunal stated that an assessment order must be interpreted as is, without assumptions or postulations. If the AO had indeed erred, avenues for correction, such as rectification under Section 154 of the Act, were available but not utilized.
Revision u/s 263 - unexplained cash deposits - The tribunal rejected the notion that unexplained deposits prior to withdrawals undermined the explanation provided by the appellant. - Regarding the PCIT's assertion of the AO's mistake in not making the addition, the tribunal stated that an assessment order must be interpreted as is, without assumptions or postulations. If the AO had indeed erred, avenues for correction, such as rectification under Section 154 of the Act, were available but not utilized.
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