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...
AO failed to conduct proper inquiry regarding alleged bogus long term capital gain by not examining bankers, brokers, Demat agencies involved in transactions, ascertaining source of funds, verifying synchronized trades, summoning person who deposited cheques in assessee's account. Connivance of bankers, brokers, Demat agencies suspected in such scams. AO directed to make larger inquiry, summon relevant parties, determine real income and rightful assessee. Matter remanded to AO for fresh adjudication after due inquiry, providing fair opportunity to assessee. Appeal allowed.
AO failed to conduct proper inquiry regarding alleged bogus long term capital gain by not examining bankers, brokers, Demat agencies involved in transactions, ascertaining source of funds, verifying synchronized trades, summoning person who deposited cheques in assessee's account. Connivance of bankers, brokers, Demat agencies suspected in such scams. AO directed to make larger inquiry, summon relevant parties, determine real income and rightful assessee. Matter remanded to AO for fresh adjudication after due inquiry, providing fair opportunity to assessee. Appeal allowed.
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