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 case involved legality of assessment u/s 153A without search or Panchnama. The search warrant named the assessee company, rejecting the objection. No incriminating material was found during search, challenging the applicability of section 153A. Unexplained cash credit additions lacked proper investigation, leading to deletion of Rs. 3,70,000 addition. Income deposited in cash was declared and documented, leading to deletion of Rs. 10,50,000 addition. Addition u/s 68 was disputed, with relief granted by CIT(A). Disallowance of depreciation on vehicle was found baseless. CIT(A) upheld unexplained cash credit appeal, rejecting Department's challenge on genuineness. Overall, Department's appeal was dismissed due to lack of merit.
The case involved legality of assessment u/s 153A without search or Panchnama. The search warrant named the assessee company, rejecting the objection. No incriminating material was found during search, challenging the applicability of section 153A. Unexplained cash credit additions lacked proper investigation, leading to deletion of Rs. 3,70,000 addition. Income deposited in cash was declared and documented, leading to deletion of Rs. 10,50,000 addition. Addition u/s 68 was disputed, with relief granted by CIT(A). Disallowance of depreciation on vehicle was found baseless. CIT(A) upheld unexplained cash credit appeal, rejecting Department's challenge on genuineness. Overall, Department's appeal was dismissed due to lack of merit.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4796
Join Channel
TaxTMI 
