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...
Ratification of resignation acceptance validates separation retrospectively, while withdrawal may be refused through reasoned administrative discretio...
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Assessment u/s 153A - addition made in respect of completed assessment in absence of any incriminating material - The tribunal found that the additions made to the taxpayer’s income for these years were not backed by any incriminating evidence obtained during the search. Citing several precedents, including a Supreme Court ruling, the Tribunal noted that additions cannot be made for completed assessment years in the absence of incriminating material. Similar to the earlier years, the Tribunal observed that the additions were based solely on statements made under distress without any corroborating material evidence.
Assessment u/s 153A - addition made in respect of completed assessment in absence of any incriminating material - The tribunal found that the additions made to the taxpayer’s income for these years were not backed by any incriminating evidence obtained during the search. Citing several precedents, including a Supreme Court ruling, the Tribunal noted that additions cannot be made for completed assessment years in the absence of incriminating material. Similar to the earlier years, the Tribunal observed that the additions were based solely on statements made under distress without any corroborating material evidence.
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