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 upheld the Revision u/s 263 by PCIT, finding the AO's assessment under section 143(3) r.w.s. 153C erroneous and prejudicial to Revenue. The unsigned assessment order in ITBA portal was deemed immaterial for invoking u/s 263. PCIT's direction for fresh assessment was justified as AO omitted to consider share profits. Proposed addition under u/s 69A was exempted u/s 10(2A) as firm was separately assessed. PCIT's direction on share of profit verification was upheld as no evidence showed it related to earlier years. PCIT's order was not cryptic and PCIT rightly found AO's assessment prejudicial to Revenue. The grounds challenging PCIT's decision were dismissed.
The ITAT upheld the Revision u/s 263 by PCIT, finding the AO's assessment under section 143(3) r.w.s. 153C erroneous and prejudicial to Revenue. The unsigned assessment order in ITBA portal was deemed immaterial for invoking u/s 263. PCIT's direction for fresh assessment was justified as AO omitted to consider share profits. Proposed addition under u/s 69A was exempted u/s 10(2A) as firm was separately assessed. PCIT's direction on share of profit verification was upheld as no evidence showed it related to earlier years. PCIT's order was not cryptic and PCIT rightly found AO's assessment prejudicial to Revenue. The grounds challenging PCIT's decision were dismissed.
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