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 Ahmedabad addressed the validity of an assessment by the AO on issues beyond those covered by a notice u/s 143(2) issued under CASS for limited scrutiny, specifically regarding immovable property under a family arrangement. The Tribunal dismissed the first ground of the assessee, noting that the notice was issued for verifying the purchase of the property in question. Regarding the addition u/s 56(2)(x) of the Act, the Tribunal found that the property was received as part of a family settlement, supported by affidavits and the concept of family arrangements as explained by the Hon'ble Supreme Court. The Tribunal held that the addition made by the AO u/s 56(2)(x) was not sustainable, partially allowing the assessee's appeal. The CIT(A) failed to appreciate the nature of the family arrangement and relevant legal precedents.
The ITAT Ahmedabad addressed the validity of an assessment by the AO on issues beyond those covered by a notice u/s 143(2) issued under CASS for limited scrutiny, specifically regarding immovable property under a family arrangement. The Tribunal dismissed the first ground of the assessee, noting that the notice was issued for verifying the purchase of the property in question. Regarding the addition u/s 56(2)(x) of the Act, the Tribunal found that the property was received as part of a family settlement, supported by affidavits and the concept of family arrangements as explained by the Hon'ble Supreme Court. The Tribunal held that the addition made by the AO u/s 56(2)(x) was not sustainable, partially allowing the assessee's appeal. The CIT(A) failed to appreciate the nature of the family arrangement and relevant legal precedents.
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