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 Jaipur, in a case involving unexplained money u/s 69A, found that the assessee, a widow running a medical retail store, deposited cash exceeding turnover. The cash was a combination of sales proceeds, loan, and turnover. The assessee, facing health challenges, relied on an accountant for tax filings. The Tribunal admitted additional evidence supporting the assessee's claim, directing the AO to compute cash credits vis-a-vis turnover. The turnover was to be examined based on corroborative evidence, with profit taxed at 8% u/s 44AD due to lack of comparative data. The AO was instructed to verify turnover using bank statements and the assessee to provide relevant documents. The appeal was allowed in favor of the assessee.
The ITAT Jaipur, in a case involving unexplained money u/s 69A, found that the assessee, a widow running a medical retail store, deposited cash exceeding turnover. The cash was a combination of sales proceeds, loan, and turnover. The assessee, facing health challenges, relied on an accountant for tax filings. The Tribunal admitted additional evidence supporting the assessee's claim, directing the AO to compute cash credits vis-a-vis turnover. The turnover was to be examined based on corroborative evidence, with profit taxed at 8% u/s 44AD due to lack of comparative data. The AO was instructed to verify turnover using bank statements and the assessee to provide relevant documents. The appeal was allowed in favor of the assessee.
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