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 u/s 68 - unsecured loans Addition u/s 2(22)(e) - Deemed dividend - The Tribunal found merit in the Assessee's submissions, noting that all relevant documents were submitted to prove the legitimacy of the transaction. The addition under section 68 was reversed, and the AO was directed to delete the same. However, the addition under section 2(22)(e) was upheld, as the Assessee failed to provide substantial evidence to support the contention that the loan from M/s KAJ Infrastructure Pvt. Ltd. was for business purposes.
Addition u/s 68 - unsecured loans Addition u/s 2(22)(e) - Deemed dividend - The Tribunal found merit in the Assessee's submissions, noting that all relevant documents were submitted to prove the legitimacy of the transaction. The addition under section 68 was reversed, and the AO was directed to delete the same. However, the addition under section 2(22)(e) was upheld, as the Assessee failed to provide substantial evidence to support the contention that the loan from M/s KAJ Infrastructure Pvt. Ltd. was for business purposes.
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