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 Delhi ruled on an assessment u/s 153A, focusing on additions u/s 68 and undisclosed sources based on the Assessee's bank statement. The Tribunal found no incriminating material during the search to support the additions. Citing precedents like Kabul Chawla and Meeta Gutgutia, the Tribunal deleted the addition. The Supreme Court in Abhisar Build well P. Ltd. held that additions without incriminating material from a search or requisition are invalid. The Assessee's appeal was allowed.
The ITAT Delhi ruled on an assessment u/s 153A, focusing on additions u/s 68 and undisclosed sources based on the Assessee's bank statement. The Tribunal found no incriminating material during the search to support the additions. Citing precedents like Kabul Chawla and Meeta Gutgutia, the Tribunal deleted the addition. The Supreme Court in Abhisar Build well P. Ltd. held that additions without incriminating material from a search or requisition are invalid. The Assessee's appeal was allowed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4796
Join Channel
TaxTMI 
