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 40A - purchases in cash in excess of ₹ 20,000/ - case of the assessee that all the cash purchase are fully covered under Rule 6DD(e)(ii) of the Income Tax Rules, as many venders do not have bank account and the purchases were done away from remote areas - whether assessee has fulfilled the condition laid down in Rule 6DD? - The Tribunal noted that the appellant had indeed made substantial cash purchases but found merit in the argument that these were covered under Rule 6DD, considering the nature of the business and the vendors' circumstances.
Addition u/s 40A - purchases in cash in excess of ₹ 20,000/ - case of the assessee that all the cash purchase are fully covered under Rule 6DD(e)(ii) of the Income Tax Rules, as many venders do not have bank account and the purchases were done away from remote areas - whether assessee has fulfilled the condition laid down in Rule 6DD? - The Tribunal noted that the appellant had indeed made substantial cash purchases but found merit in the argument that these were covered under Rule 6DD, considering the nature of the business and the vendors' circumstances.
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