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, an Appellate Tribunal, ruled on unexplained cash deposits in bank accounts opened by a CA misusing KYC documents. The CA, acting fraudulently, used the taxpayer's ID to open accounts, obtain loans, and acquire properties. Following a Rs. 2000 cr fraud discovery, involving multiple arrests, it was found that the CA was the mastermind. The Tribunal held that the additions to the taxpayer's account were unjustified, as the CA was responsible for the transactions. The AO failed to verify key forms and neglected to summon relevant parties. The taxpayer successfully demonstrated that the accounts were not theirs, leading to a decision in their favor. The cash deposits were attributed to the CA, exonerating the taxpayer.
The ITAT, an Appellate Tribunal, ruled on unexplained cash deposits in bank accounts opened by a CA misusing KYC documents. The CA, acting fraudulently, used the taxpayer's ID to open accounts, obtain loans, and acquire properties. Following a Rs. 2000 cr fraud discovery, involving multiple arrests, it was found that the CA was the mastermind. The Tribunal held that the additions to the taxpayer's account were unjustified, as the CA was responsible for the transactions. The AO failed to verify key forms and neglected to summon relevant parties. The taxpayer successfully demonstrated that the accounts were not theirs, leading to a decision in their favor. The cash deposits were attributed to the CA, exonerating the taxpayer.
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