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...
Loose papers found during a search at the residences of individuals contained notings and calculations presumed by the Assessing Officer (AO) to relate to undisclosed income and investments of one individual. However, the evidence failed to establish any connection between the notings and that individual's activities or sources of income. The notings pertained to expenses, vehicle purchases, and numerical entries, but no regular income was identified for that person to correlate with such expenses. The loose papers were found at another individual's residence, whose business records were accepted. The Tribunal held that the AO wrongly attributed the loose paper notings to the first individual without establishing any link or means of income, when they likely related to the second individual's accepted business. Consequently, the additions made by the AO based on the loose papers were deleted for lack of credible evidence connecting them to the first individual's undisclosed income or investments.
Loose papers found during a search at the residences of individuals contained notings and calculations presumed by the Assessing Officer (AO) to relate to undisclosed income and investments of one individual. However, the evidence failed to establish any connection between the notings and that individual's activities or sources of income. The notings pertained to expenses, vehicle purchases, and numerical entries, but no regular income was identified for that person to correlate with such expenses. The loose papers were found at another individual's residence, whose business records were accepted. The Tribunal held that the AO wrongly attributed the loose paper notings to the first individual without establishing any link or means of income, when they likely related to the second individual's accepted business. Consequently, the additions made by the AO based on the loose papers were deleted for lack of credible evidence connecting them to the first individual's undisclosed income or investments.
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