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...
Validity of reopening the assessment u/s 147 - Additions u/s 68 and u/s 69A - Cash deposits in assessee’s bank account - The ITAT observed that, the AO was satisfied that the assessee owned agricultural land and sold the same during this assessment year - The Tribunal concluded that the reopening of the assessment was valid, but the additions made by the AO and CIT(A) were not justified as the assessee had sufficiently explained the source of cash deposits. The appeal was partly allowed, and the additions made u/s 68 and 69A were set aside.
Validity of reopening the assessment u/s 147 - Additions u/s 68 and u/s 69A - Cash deposits in assessee’s bank account - The ITAT observed that, the AO was satisfied that the assessee owned agricultural land and sold the same during this assessment year - The Tribunal concluded that the reopening of the assessment was valid, but the additions made by the AO and CIT(A) were not justified as the assessee had sufficiently explained the source of cash deposits. The appeal was partly allowed, and the additions made u/s 68 and 69A were set aside.
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