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...
Section 69A addition for unexplained income treated as advances was rightly deleted as the loan amounts were recorded in books, supported by bank statements and confirmations, even if details of immovable property transaction were unavailable. The assessee was not the owner of unrecorded assets, satisfying Section 69A conditions. CIT(A) rightly deleted the addition after considering all aspects. Addition of Rs. 1.70 crores relating to Outstripe Suppliers Pvt. Ltd. transaction was part of Rs. 2 crores addition for the same transaction in the previous year, leading to double addition, hence rightly deleted by CIT(A).
Section 69A addition for unexplained income treated as advances was rightly deleted as the loan amounts were recorded in books, supported by bank statements and confirmations, even if details of immovable property transaction were unavailable. The assessee was not the owner of unrecorded assets, satisfying Section 69A conditions. CIT(A) rightly deleted the addition after considering all aspects. Addition of Rs. 1.70 crores relating to Outstripe Suppliers Pvt. Ltd. transaction was part of Rs. 2 crores addition for the same transaction in the previous year, leading to double addition, hence rightly deleted by CIT(A).
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