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...
Cash deposits during the demonetization period were recorded in the books of accounts, with the source maintained. The Assessing Officer invoked Section 69A and charged tax u/s 115BBE, treating the deposits as unexplained money. However, Section 69A is applicable when the assessee is the owner of money, bullion, jewelry, or valuable articles not recorded from any source. Since the cash deposits were recorded with the source maintained, invoking Section 69A was incorrect. Consequently, the addition made by the Assessing Officer is liable to be deleted, and the decision is in favor of the assessee.
Cash deposits during the demonetization period were recorded in the books of accounts, with the source maintained. The Assessing Officer invoked Section 69A and charged tax u/s 115BBE, treating the deposits as unexplained money. However, Section 69A is applicable when the assessee is the owner of money, bullion, jewelry, or valuable articles not recorded from any source. Since the cash deposits were recorded with the source maintained, invoking Section 69A was incorrect. Consequently, the addition made by the Assessing Officer is liable to be deleted, and the decision is in favor of the assessee.
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