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...
The High Court dismissed the appeal filed u/s 260A, holding that no substantial question of law arises. The Assessing Officer had rejected the assessee's books of accounts and applied a low gross profit rate of 0.54% without valid reasons. The Income Tax Appellate Tribunal (ITAT) observed that the assessee had produced stock statements without negative stock, and the evidence was part of the account books furnished. The ITAT held that it was unjustified to reject accounts merely because buyers' names were not mentioned in cash sales bills, as the assessee traded in gold bullion where rates were ascertainable. The ITAT found no valid reason to doubt the assessee's records, as they maintained quantitative stock tally. The Revenue failed to establish that the assessee did not adopt a consistent accounting method or that profits could not be detected from the books. The High Court upheld the ITAT's findings based on the factual matrix and documents examined by the lower authorities.
The High Court dismissed the appeal filed u/s 260A, holding that no substantial question of law arises. The Assessing Officer had rejected the assessee's books of accounts and applied a low gross profit rate of 0.54% without valid reasons. The Income Tax Appellate Tribunal (ITAT) observed that the assessee had produced stock statements without negative stock, and the evidence was part of the account books furnished. The ITAT held that it was unjustified to reject accounts merely because buyers' names were not mentioned in cash sales bills, as the assessee traded in gold bullion where rates were ascertainable. The ITAT found no valid reason to doubt the assessee's records, as they maintained quantitative stock tally. The Revenue failed to establish that the assessee did not adopt a consistent accounting method or that profits could not be detected from the books. The High Court upheld the ITAT's findings based on the factual matrix and documents examined by the lower authorities.
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