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 68 - unexplained share application money - genuineness and creditworthiness of the share capital subscription challenged - ITAT deleted addition - The Delhi High Court upheld the decisions of the ITAT, which had favorably considered the assessee's appeals against the substantial additions imposed by the Assessing Officer. The court found that the ITAT had correctly applied the legal principles to the facts, which were thoroughly vetted and substantiated by adequate evidence. Thus, no substantial questions of law arose from the ITAT’s decisions, leading to the dismissal of the Revenue's appeals
Addition u/s 68 - unexplained share application money - genuineness and creditworthiness of the share capital subscription challenged - ITAT deleted addition - The Delhi High Court upheld the decisions of the ITAT, which had favorably considered the assessee's appeals against the substantial additions imposed by the Assessing Officer. The court found that the ITAT had correctly applied the legal principles to the facts, which were thoroughly vetted and substantiated by adequate evidence. Thus, no substantial questions of law arose from the ITAT’s decisions, leading to the dismissal of the Revenue's appeals
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