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 of contract receipts - bogus activity - Estimation of income - The AO had made an addition to the assessee's income, alleging discrepancies in the contract receipts and estimating the profit at 8%. However, upon careful consideration, the Tribunal found inconsistencies in the assessment. It questioned the basis for estimating profit at 8% when the commission ranged from 0.25% to 1%, and the discrepancy regarding the actual contract receipts. The Tribunal concluded that the addition lacked demonstrative evidence and was based on surmise and conjecture.
Addition of contract receipts - bogus activity - Estimation of income - The AO had made an addition to the assessee's income, alleging discrepancies in the contract receipts and estimating the profit at 8%. However, upon careful consideration, the Tribunal found inconsistencies in the assessment. It questioned the basis for estimating profit at 8% when the commission ranged from 0.25% to 1%, and the discrepancy regarding the actual contract receipts. The Tribunal concluded that the addition lacked demonstrative evidence and was based on surmise and conjecture.
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