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...
Bogus purchases - Burden of proof - The Tribunal found that the assessee had adequately demonstrated the genuineness of purchases through detailed documentation and accounting records. The purchases were correlated with corresponding sales, further validating their authenticity. - The Tribunal noted the absence of an opportunity for cross-examination regarding the supplier's statement, emphasizing the importance of procedural fairness. Without proper validation, the statement lacked evidentiary weight. - The absence of incriminating evidence during the search further bolstered the assessee's case. - Ultimately, the ITAT dismissed the Revenue's appeal.
Bogus purchases - Burden of proof - The Tribunal found that the assessee had adequately demonstrated the genuineness of purchases through detailed documentation and accounting records. The purchases were correlated with corresponding sales, further validating their authenticity. - The Tribunal noted the absence of an opportunity for cross-examination regarding the supplier's statement, emphasizing the importance of procedural fairness. Without proper validation, the statement lacked evidentiary weight. - The absence of incriminating evidence during the search further bolstered the assessee's case. - Ultimately, the ITAT dismissed the Revenue's appeal.
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