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...
Assessment proceedings initiated against a person who had died - Unexplained cash credit u/s 68 r.w.s. 115BBE - assessee has failed to prove the genuineness of amount deposited in bank accounts in OHD was from the sale of petrol and oil made during the demonetization period - The court found that the assessment order was invalid due to being issued against a deceased person, and therefore, quashed it. Consequently, as the assessment order was quashed, all other issues regarding additions made by the Assessing Officer became academic and were rendered infructuous.
Assessment proceedings initiated against a person who had died - Unexplained cash credit u/s 68 r.w.s. 115BBE - assessee has failed to prove the genuineness of amount deposited in bank accounts in OHD was from the sale of petrol and oil made during the demonetization period - The court found that the assessment order was invalid due to being issued against a deceased person, and therefore, quashed it. Consequently, as the assessment order was quashed, all other issues regarding additions made by the Assessing Officer became academic and were rendered infructuous.
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