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...
The ITAT Jodhpur dealt with a case involving addition u/s 68 of the Income Tax Act concerning alleged bogus share application money. The Investigation Wing provided specific information, but the CIT(A) deleted the addition after finding the investor companies' identity, creditworthiness, and genuineness were proven by the assessee. The tribunal upheld the CIT(A)'s decision, stating the AO lacked a basis for the addition. The commission expenses for the alleged bogus share application money were deemed unnecessary due to the genuine nature of the funds. The reassessment proceedings' validity was not directly addressed by the CIT(A) but was considered decided against the assessee based on a legal precedent. The tribunal allowed the assessee to argue the reassessment issue despite not appealing the CIT(A)'s decision, in line with ITAT Rules.
The ITAT Jodhpur dealt with a case involving addition u/s 68 of the Income Tax Act concerning alleged bogus share application money. The Investigation Wing provided specific information, but the CIT(A) deleted the addition after finding the investor companies' identity, creditworthiness, and genuineness were proven by the assessee. The tribunal upheld the CIT(A)'s decision, stating the AO lacked a basis for the addition. The commission expenses for the alleged bogus share application money were deemed unnecessary due to the genuine nature of the funds. The reassessment proceedings' validity was not directly addressed by the CIT(A) but was considered decided against the assessee based on a legal precedent. The tribunal allowed the assessee to argue the reassessment issue despite not appealing the CIT(A)'s decision, in line with ITAT Rules.
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