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 Surat dealt with a case involving unexplained credit u/s 68. The assessee received a commission of 0.50% per Rs. 100 but failed to provide details of transactions or persons involved. The Tribunal noted the absence of specific details and the peculiar nature of the business. Previous cases were cited where additions were restricted to 0.125% to 0.35%. Following a consistent approach, the Tribunal limited the addition to Rs. 75 per lakh, equivalent to 0.75% for Rs. 100. The total credit in the bank account was found to be Rs. 2.07 crores after considering cheque and cash deposits. The Tribunal allowed the appeal partly, directing the assessing officer to adjust the assessment accordingly.
The ITAT Surat dealt with a case involving unexplained credit u/s 68. The assessee received a commission of 0.50% per Rs. 100 but failed to provide details of transactions or persons involved. The Tribunal noted the absence of specific details and the peculiar nature of the business. Previous cases were cited where additions were restricted to 0.125% to 0.35%. Following a consistent approach, the Tribunal limited the addition to Rs. 75 per lakh, equivalent to 0.75% for Rs. 100. The total credit in the bank account was found to be Rs. 2.07 crores after considering cheque and cash deposits. The Tribunal allowed the appeal partly, directing the assessing officer to adjust the assessment accordingly.
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