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 Bangalore addressed unexplained cash deposits u/s 69A, focusing on the credibility of earlier withdrawals as a source for redeposits. The Tribunal examined fund flow and cash flow statements, presuming cash availability for redeposit. The assessee deposited sums during demonetization, providing bank account details, rent agreements, and rental income confirmation. The assessee explained using earlier withdrawals and tenant payments for redeposits, supported by the case of S.R. Venkataratnam. The Tribunal ruled in favor of the assessee, allowing credit for cash withdrawals and rental income towards bank deposits, deleting the addition for unexplained cash deposits during demonetization.
The ITAT Bangalore addressed unexplained cash deposits u/s 69A, focusing on the credibility of earlier withdrawals as a source for redeposits. The Tribunal examined fund flow and cash flow statements, presuming cash availability for redeposit. The assessee deposited sums during demonetization, providing bank account details, rent agreements, and rental income confirmation. The assessee explained using earlier withdrawals and tenant payments for redeposits, supported by the case of S.R. Venkataratnam. The Tribunal ruled in favor of the assessee, allowing credit for cash withdrawals and rental income towards bank deposits, deleting the addition for unexplained cash deposits during demonetization.
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