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 - share application money received as unaccounted cash credit - identity and creditworthiness of the share subscribers and genuineness of the transaction - The case involved an appeal filed by the Revenue against the deletion of an addition made under section 68 of the Income Tax Act regarding share capital and premium received by the Assessee. The Revenue argued that the transaction was not adequately explained and deemed to be bogus. However, the Tribunal upheld the decision to delete the addition, as the Assessee provided sufficient evidence to prove the genuineness of the transaction and the credibility of the share applicants.
Addition u/s 68 - share application money received as unaccounted cash credit - identity and creditworthiness of the share subscribers and genuineness of the transaction - The case involved an appeal filed by the Revenue against the deletion of an addition made under section 68 of the Income Tax Act regarding share capital and premium received by the Assessee. The Revenue argued that the transaction was not adequately explained and deemed to be bogus. However, the Tribunal upheld the decision to delete the addition, as the Assessee provided sufficient evidence to prove the genuineness of the transaction and the credibility of the share applicants.
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