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 u/s 40A(3) - Cash expenditure - assessee has made payments to the land owners exceeding INR 20,000/- - The Tribunal agreed with the appellant's argument to some extent, acknowledging that the disallowance should have been restricted to 20% of the total expenditure exceeding the prescribed limit. While the appellant failed to provide substantial evidence of business expediency, the Tribunal recognized that the disallowance should adhere to the provisions of section 40A(3), limiting it to 20%.
Addition u/s 40A(3) - Cash expenditure - assessee has made payments to the land owners exceeding INR 20,000/- - The Tribunal agreed with the appellant's argument to some extent, acknowledging that the disallowance should have been restricted to 20% of the total expenditure exceeding the prescribed limit. While the appellant failed to provide substantial evidence of business expediency, the Tribunal recognized that the disallowance should adhere to the provisions of section 40A(3), limiting it to 20%.
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