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...
Ratification of resignation acceptance validates separation retrospectively, while withdrawal may be refused through reasoned administrative discretio...
Addition u/s 68 - ITAT confirmed the additions - The High Court upheld the Tribunal's decision, affirming the dismissal of the appeal. It concurred with the Tribunal's analysis, emphasizing that the assessment of income tax is a civil proceeding, wherein the test of preponderance of probability is applicable. The Court agreed that the explanation provided by the appellant regarding the gifts lacked sufficient evidence of genuineness. It noted the absence of any disclosed basis or relationship for the gifts, reinforcing the Tribunal's decision.
Addition u/s 68 - ITAT confirmed the additions - The High Court upheld the Tribunal's decision, affirming the dismissal of the appeal. It concurred with the Tribunal's analysis, emphasizing that the assessment of income tax is a civil proceeding, wherein the test of preponderance of probability is applicable. The Court agreed that the explanation provided by the appellant regarding the gifts lacked sufficient evidence of genuineness. It noted the absence of any disclosed basis or relationship for the gifts, reinforcing the Tribunal's decision.
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