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...
Bogus share transactions involving abnormal price rise in penny stock shares - Assessee produced evidence of share purchase, existence in demat account - AO failed to rebut assessee's evidence, merely relied on circumstantial evidence - Ignorance of assessee about company's financials not crucial when transactions substantiated - Denial of exemption u/s 10(38) not justified - Addition u/s 68 deleted by CIT(A), upheld by ITAT - AO should have discharged onus after assessee's evidence.
Bogus share transactions involving abnormal price rise in penny stock shares - Assessee produced evidence of share purchase, existence in demat account - AO failed to rebut assessee's evidence, merely relied on circumstantial evidence - Ignorance of assessee about company's financials not crucial when transactions substantiated - Denial of exemption u/s 10(38) not justified - Addition u/s 68 deleted by CIT(A), upheld by ITAT - AO should have discharged onus after assessee's evidence.
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