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...
Additions based on Cash Expenditure - Disclosure were made by the appellant in IDS - The Tribunal ruled in favor of the appellant, holding that the entries did not warrant additional taxation. It noted that the expenses were from known sources and reconciled with existing books, thus not constituting unexplained expenditure under section 69C. Moreover, it accepted the appellant's claim regarding the disclosure under the Income Declaration Scheme, 2016, ruling that the expenses should not be treated as taxable income.
Additions based on Cash Expenditure - Disclosure were made by the appellant in IDS - The Tribunal ruled in favor of the appellant, holding that the entries did not warrant additional taxation. It noted that the expenses were from known sources and reconciled with existing books, thus not constituting unexplained expenditure under section 69C. Moreover, it accepted the appellant's claim regarding the disclosure under the Income Declaration Scheme, 2016, ruling that the expenses should not be treated as taxable income.
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