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...
Addition u/s 68 for director's loan ledger account was made by assessing officer (AO) considering transactions not matching previous year's financial statements. Assessee stated transactions pertained to prior assessment years. Tribunal held previous year's transactions cannot be considered income in current assessment year. Transactions related to FY 2012-13 and 2013-14, for which AO passed order u/s 143(3) on 29.01.2016 accepting closing balance of director's ledger account. AO cannot consider opening balance in current assessment year for making addition, relying on Sridev Enterprises judgment. Tribunal upheld CIT(Appeals) order deleting the addition, decided in favor of assessee.
Addition u/s 68 for director's loan ledger account was made by assessing officer (AO) considering transactions not matching previous year's financial statements. Assessee stated transactions pertained to prior assessment years. Tribunal held previous year's transactions cannot be considered income in current assessment year. Transactions related to FY 2012-13 and 2013-14, for which AO passed order u/s 143(3) on 29.01.2016 accepting closing balance of director's ledger account. AO cannot consider opening balance in current assessment year for making addition, relying on Sridev Enterprises judgment. Tribunal upheld CIT(Appeals) order deleting the addition, decided in favor of assessee.
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