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 of bogus sales - difference in opinion between learned Members constituting the bench - The appellate tribunal (Third Member) addressed the dispute arising from alleged bogus sales transactions during the demonetization period. The Assessing Officer treated these transactions as unexplained cash credit under Section 68 of the Income Tax Act. However, the Tribunal found that the assessee sufficiently proved the authenticity of the sales through meticulous record-keeping and documentary evidence, despite challenges such as non-responses from some parties and allegations of sham transactions. - The Third Member upheld the decision of the learned Accountant Member to reject the addition under Section 68, considering the adequacy of evidence presented by the assessee.
Addition of bogus sales - difference in opinion between learned Members constituting the bench - The appellate tribunal (Third Member) addressed the dispute arising from alleged bogus sales transactions during the demonetization period. The Assessing Officer treated these transactions as unexplained cash credit under Section 68 of the Income Tax Act. However, the Tribunal found that the assessee sufficiently proved the authenticity of the sales through meticulous record-keeping and documentary evidence, despite challenges such as non-responses from some parties and allegations of sham transactions. - The Third Member upheld the decision of the learned Accountant Member to reject the addition under Section 68, considering the adequacy of evidence presented by the assessee.
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