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...
Income from undisclosed sources - addition of agricultural income - Assessment of agricultural income declared by the assessee for various assessment years was questioned by the Assessing Officer, leading to additions to total income as income from undisclosed sources. - The tribunal observed that on looking at the holding of the agricultural records of land holding, the agricultural produce mentioned there in and some of the bills of APMC produced before us clearly show that assessee is engaged in agricultural activities. - Additions made to the total income regarding the cash found in the locker and agricultural income were deemed unsustainable based on the evidence presented.
Income from undisclosed sources - addition of agricultural income - Assessment of agricultural income declared by the assessee for various assessment years was questioned by the Assessing Officer, leading to additions to total income as income from undisclosed sources. - The tribunal observed that on looking at the holding of the agricultural records of land holding, the agricultural produce mentioned there in and some of the bills of APMC produced before us clearly show that assessee is engaged in agricultural activities. - Additions made to the total income regarding the cash found in the locker and agricultural income were deemed unsustainable based on the evidence presented.
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