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 assessing officer (AO) made additions to the assessee's income based on alleged bogus purchases and unexplained investments. The key points are: Addition of Rs. 209.82 lacs under 'others' category was rightly deleted by CIT(A) due to lack of proper findings. Out of total purchases, Rs. 5,11,56,526 were from 4 entirely bogus parties, while Rs. 5,35,20,325 were partially bogus from 15 parties. Since the assessee offered Rs. 5,53,25,652 as additional income, and considering 10% leakage on partially bogus purchases, the net addition sustained is Rs. 11,82,906. Disallowance of sub-contractor's expenses of Rs. 157 lacs was upheld, as the assessee admitted only Rs. 140.18 lacs, and the GST component was adjusted against output liability. Addition of unexplained investment u/s 69, based solely on loose excel sheets found during search, was deleted following the ITAT's decision in Kranti Impex case, which held that undated, unsigned papers cannot be the sole basis for determining undisclosed income.
The assessing officer (AO) made additions to the assessee's income based on alleged bogus purchases and unexplained investments. The key points are: Addition of Rs. 209.82 lacs under 'others' category was rightly deleted by CIT(A) due to lack of proper findings. Out of total purchases, Rs. 5,11,56,526 were from 4 entirely bogus parties, while Rs. 5,35,20,325 were partially bogus from 15 parties. Since the assessee offered Rs. 5,53,25,652 as additional income, and considering 10% leakage on partially bogus purchases, the net addition sustained is Rs. 11,82,906. Disallowance of sub-contractor's expenses of Rs. 157 lacs was upheld, as the assessee admitted only Rs. 140.18 lacs, and the GST component was adjusted against output liability. Addition of unexplained investment u/s 69, based solely on loose excel sheets found during search, was deleted following the ITAT's decision in Kranti Impex case, which held that undated, unsigned papers cannot be the sole basis for determining undisclosed income.
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