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...
Unexplained cash credit u/s 68 - bogus share capital/share premium - The tribunal noted that the appellant's company had witnessed significant growth over the years, leading to a substantial increase in the value of its shares. The ITAT also considered the financial status of the share subscribers, who demonstrated ample net worth to justify their investments. - Furthermore, the ITAT emphasized that the provisions of Section 56(2)(viib) of the Act, relating to the valuation of shares, were not applicable to the assessment year in question. It was concluded that the addition of the unexplained cash credit was unjustified.
Unexplained cash credit u/s 68 - bogus share capital/share premium - The tribunal noted that the appellant's company had witnessed significant growth over the years, leading to a substantial increase in the value of its shares. The ITAT also considered the financial status of the share subscribers, who demonstrated ample net worth to justify their investments. - Furthermore, the ITAT emphasized that the provisions of Section 56(2)(viib) of the Act, relating to the valuation of shares, were not applicable to the assessment year in question. It was concluded that the addition of the unexplained cash credit was unjustified.
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