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...
Estimation of income - bogus purchases - quantification of profit - The Tribunal noted that during investigations, the alleged suppliers were identified as bogus entities involved in issuing fake invoices without actual delivery of goods. Despite the taxpayer’s claims of making payments through banking channels, the assessing officer found no credible evidence to support the genuineness of the transactions. Consequently, the Tribunal agreed with the lower authorities in treating these purchases as bogus but redirected the case to assess the exact profit element attributable to these transactions, aligning with the principle that only the profit margin on such bogus transactions should be added to taxable income.
Estimation of income - bogus purchases - quantification of profit - The Tribunal noted that during investigations, the alleged suppliers were identified as bogus entities involved in issuing fake invoices without actual delivery of goods. Despite the taxpayer’s claims of making payments through banking channels, the assessing officer found no credible evidence to support the genuineness of the transactions. Consequently, the Tribunal agreed with the lower authorities in treating these purchases as bogus but redirected the case to assess the exact profit element attributable to these transactions, aligning with the principle that only the profit margin on such bogus transactions should be added to taxable income.
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