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 considered the validity of an order u/s 143(1)(a) where the AO made adjustments based on the tax auditor's entry for penalty or fine. The AO communicated the proposed adjustment and provided reasons in the intimation order. The ITAT referenced the distinction between intimation and assessment per the Supreme Court's ruling in CIT Vs Rajesh Jhaveri Stock Brokers P ltd. The AO's authority is limited to adjustments based on the return of income, not debatable issues. In this case, the AO's actions were deemed appropriate as the adjustment was based on a prima facie disallowable amount categorized by the tax auditor. The appeal was allowed for statistical purposes. The decision aligns with legal principles governing adjustments u/s 143(1)(a).
The ITAT considered the validity of an order u/s 143(1)(a) where the AO made adjustments based on the tax auditor's entry for penalty or fine. The AO communicated the proposed adjustment and provided reasons in the intimation order. The ITAT referenced the distinction between intimation and assessment per the Supreme Court's ruling in CIT Vs Rajesh Jhaveri Stock Brokers P ltd. The AO's authority is limited to adjustments based on the return of income, not debatable issues. In this case, the AO's actions were deemed appropriate as the adjustment was based on a prima facie disallowable amount categorized by the tax auditor. The appeal was allowed for statistical purposes. The decision aligns with legal principles governing adjustments u/s 143(1)(a).
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