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 Delhi held that the addition for unexplained investment made to a company was unjustified. The Tribunal found that the total investments were made through a banking channel, specifically after withdrawals from an Axis Bank Account. The source of deposits in the account was explained and admitted, making the addition on account of withdrawals irrational. The addition from an undisclosed source related to a bridal business was based on suspicion, with the AO and CIT(A) erroneously holding 30% of deposits. The Tribunal considered the nature of the business and calculated the security amount at 10% of the hire charges. The assessee satisfactorily explained the bank entries, leading to the appeal being allowed due to a miscarriage of justice.
The ITAT Delhi held that the addition for unexplained investment made to a company was unjustified. The Tribunal found that the total investments were made through a banking channel, specifically after withdrawals from an Axis Bank Account. The source of deposits in the account was explained and admitted, making the addition on account of withdrawals irrational. The addition from an undisclosed source related to a bridal business was based on suspicion, with the AO and CIT(A) erroneously holding 30% of deposits. The Tribunal considered the nature of the business and calculated the security amount at 10% of the hire charges. The assessee satisfactorily explained the bank entries, leading to the appeal being allowed due to a miscarriage of justice.
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