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 56(2) - “Property” as defined in explanation (d) (ii) of section 56(2)(vii) makes distinction between the existing shares i.e. the shares already allotted by the company and those share which are pending allotment or not? - application of admission of additional evidence - The Tribunal observed that the issues raised were decided on merits, considering facts and applicable laws. However, due to additional information and grounds presented by the assessee, which were not available to the lower authorities, the Tribunal found it just to restore the matter to the file of the CIT(A) for fresh adjudication.
Addition u/s 56(2) - “Property” as defined in explanation (d) (ii) of section 56(2)(vii) makes distinction between the existing shares i.e. the shares already allotted by the company and those share which are pending allotment or not? - application of admission of additional evidence - The Tribunal observed that the issues raised were decided on merits, considering facts and applicable laws. However, due to additional information and grounds presented by the assessee, which were not available to the lower authorities, the Tribunal found it just to restore the matter to the file of the CIT(A) for fresh adjudication.
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