Pure-agent exclusion fails where hotel booking facilitators receive third-party services themselves, making entire customer consideration taxable as r...
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...
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Addition u/s 69A - unsecured loans - interest expenditure - The case involved disputes over the addition of unsecured loans under section 69A and the disallowance of interest expenses. The assessee provided adequate documentation to prove the genuineness of the loans and the business purpose of interest payments. Consequently, both additions made by the assessing officer were overturned, and the appeal of the assessee was allowed by the appellate tribunal.
Addition u/s 69A - unsecured loans - interest expenditure - The case involved disputes over the addition of unsecured loans under section 69A and the disallowance of interest expenses. The assessee provided adequate documentation to prove the genuineness of the loans and the business purpose of interest payments. Consequently, both additions made by the assessing officer were overturned, and the appeal of the assessee was allowed by the appellate tribunal.
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