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 being 10 percent out of various expenses - books of assessee are duly audited under section 44AB of the Act - The Appellate Tribunal upheld the arguments presented by the assessee. They noted that the books of account were audited under section 44AB of the Income Tax Act and were not rejected by the AO. Therefore, the adhoc disallowance based on presumptions was deemed unsustainable, citing the precedent set by the Supreme Court. - The Tribunal emphasized that the AO's failure to reject the books of account further weakened the basis for the adhoc disallowance.
Addition being 10 percent out of various expenses - books of assessee are duly audited under section 44AB of the Act - The Appellate Tribunal upheld the arguments presented by the assessee. They noted that the books of account were audited under section 44AB of the Income Tax Act and were not rejected by the AO. Therefore, the adhoc disallowance based on presumptions was deemed unsustainable, citing the precedent set by the Supreme Court. - The Tribunal emphasized that the AO's failure to reject the books of account further weakened the basis for the adhoc disallowance.
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