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 u/s 153A - addition u/s 68 - The assessee contended that the additions were not based on any incriminating material found during the search. The Tribunal held that no addition could be made under Section 153A in the absence of incriminating material for the years where no assessment was pending. The court accepted this contention and deleted the additions. - The ITAT examined several additions and disallowances made by the assessing officer, including those related to cash deposits, unsecured loans, and depreciation on vehicles. In each instance, the court meticulously evaluated the submissions, documentary evidence, and legal positions before rendering its decisions, often in favor of the assessee by deleting unjustified additions.
Assessment u/s 153A - addition u/s 68 - The assessee contended that the additions were not based on any incriminating material found during the search. The Tribunal held that no addition could be made under Section 153A in the absence of incriminating material for the years where no assessment was pending. The court accepted this contention and deleted the additions. - The ITAT examined several additions and disallowances made by the assessing officer, including those related to cash deposits, unsecured loans, and depreciation on vehicles. In each instance, the court meticulously evaluated the submissions, documentary evidence, and legal positions before rendering its decisions, often in favor of the assessee by deleting unjustified additions.
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