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 - bogus LTCG - share capital and share premium were merely paper credit entries - receipt of accommodation entries in lieu of commission paid - The Tribunal found that the amounts received by BCPL were passed through various entities without actual business transactions, acting merely as accommodation entries. It was determined that these funds should not be treated as income of BCPL. Instead, only the commission income received for facilitating these transactions should be taxed.
Addition u/s 68 - bogus LTCG - share capital and share premium were merely paper credit entries - receipt of accommodation entries in lieu of commission paid - The Tribunal found that the amounts received by BCPL were passed through various entities without actual business transactions, acting merely as accommodation entries. It was determined that these funds should not be treated as income of BCPL. Instead, only the commission income received for facilitating these transactions should be taxed.
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