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...
Denial of exemption u/s 10(23C)(iiiad), addition of unexplained cash credits u/s 69A. Registration granted u/s 12AA from 23-02-2019 indicating trust not exclusively engaged in education. Assessing Officer treated trust as Association of Persons, rendering income from cash deposits taxable due to lack of registration u/s 12A. Assessee's contention regarding cash deposits relating to hostel receipts from third parties not substantiated by documentary evidence or formal agreement. Income from cash deposits to be considered in hands of trust in absence of supporting documentation. Commissioner of Income Tax (Appeals) directed to re-examine classification as Association of Persons and tax implications, ensuring income without third-party attribution is taxed in hands of trust. Order of Commissioner of Income Tax (Appeals) set aside, matter remitted for fresh adjudication as per law after considering facts, evidence, and submissions. Appeal allowed for statistical purposes.
Denial of exemption u/s 10(23C)(iiiad), addition of unexplained cash credits u/s 69A. Registration granted u/s 12AA from 23-02-2019 indicating trust not exclusively engaged in education. Assessing Officer treated trust as Association of Persons, rendering income from cash deposits taxable due to lack of registration u/s 12A. Assessee's contention regarding cash deposits relating to hostel receipts from third parties not substantiated by documentary evidence or formal agreement. Income from cash deposits to be considered in hands of trust in absence of supporting documentation. Commissioner of Income Tax (Appeals) directed to re-examine classification as Association of Persons and tax implications, ensuring income without third-party attribution is taxed in hands of trust. Order of Commissioner of Income Tax (Appeals) set aside, matter remitted for fresh adjudication as per law after considering facts, evidence, and submissions. Appeal allowed for statistical purposes.
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