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...
Assessee failed to file return of income u/s 139 but received notice u/s 148. Despite opting for presumptive taxation scheme u/s 44AD, which does not require maintaining books of accounts, assessee was liable to maintain books as stipulated u/s 44AA. Assessee cannot claim benefit of not complying with Section 68 regarding unexplained cash deposits in bank account. Assessee was required to explain sources, genuineness, and creditors' creditworthiness regarding cash deposits as per Section 68. Failing to do so, authorities rightly invoked Section 68 and added cash deposits as assessee's income under its deeming fiction. Case laws relied upon by assessee were decided on their own facts and inapplicable. Assessee's appeal dismissed.
Assessee failed to file return of income u/s 139 but received notice u/s 148. Despite opting for presumptive taxation scheme u/s 44AD, which does not require maintaining books of accounts, assessee was liable to maintain books as stipulated u/s 44AA. Assessee cannot claim benefit of not complying with Section 68 regarding unexplained cash deposits in bank account. Assessee was required to explain sources, genuineness, and creditors' creditworthiness regarding cash deposits as per Section 68. Failing to do so, authorities rightly invoked Section 68 and added cash deposits as assessee's income under its deeming fiction. Case laws relied upon by assessee were decided on their own facts and inapplicable. Assessee's appeal dismissed.
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