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...
Bogus loss from trading in shares/securities - ITAT observed that, despite the appellant's submission of evidences during the assessment proceedings, the assessing officer did not conduct any inquiry or investigation and solely relied on the statement of the director of the appellant company, recorded during a summon under section 131 of the Act. However, this statement was retracted by filing an affidavit, highlighting its lack of evidentiary value without corroborative evidence. - Consequently, the Tribunal allowed the appeal, directing the assessing officer to delete the addition on account of the rejection of loss.
Bogus loss from trading in shares/securities - ITAT observed that, despite the appellant's submission of evidences during the assessment proceedings, the assessing officer did not conduct any inquiry or investigation and solely relied on the statement of the director of the appellant company, recorded during a summon under section 131 of the Act. However, this statement was retracted by filing an affidavit, highlighting its lack of evidentiary value without corroborative evidence. - Consequently, the Tribunal allowed the appeal, directing the assessing officer to delete the addition on account of the rejection of loss.
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