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...
In the ITAT Delhi case, the Appellate Tribunal ruled in favor of the assessee on two key issues. Firstly, regarding unexplained cash deposits u/s 68, the AO's failure to consider cash balances and debtor realizations led to the addition being deemed unsustainable. The Tribunal directed the AO to delete the addition. Secondly, on the disallowance of interest paid u/s 36(1)(iii), the Tribunal accepted the assessee's argument that interest on bank loans is a business expenditure, given the assessee's history of real estate and finance business activities. The disallowance made by the AO was deleted based on the Tribunal's decision for the assessment year 2009-10, affirming the assessee's real estate business activities.
In the ITAT Delhi case, the Appellate Tribunal ruled in favor of the assessee on two key issues. Firstly, regarding unexplained cash deposits u/s 68, the AO's failure to consider cash balances and debtor realizations led to the addition being deemed unsustainable. The Tribunal directed the AO to delete the addition. Secondly, on the disallowance of interest paid u/s 36(1)(iii), the Tribunal accepted the assessee's argument that interest on bank loans is a business expenditure, given the assessee's history of real estate and finance business activities. The disallowance made by the AO was deleted based on the Tribunal's decision for the assessment year 2009-10, affirming the assessee's real estate business activities.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4798
Join Channel
TaxTMI 
