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 case pertains to the reopening of assessment u/s 147 regarding income related to a Non-Resident External (NRE) Account. The assessee argued that the source of income and deposits were from the NRE Account, and therefore, not taxable in India. The bank details and statements provided by the assessee revealed that the remittance of the loan was made from the NRE Account, substantiating the source of income. As per Section 10(4)(ii) of the Income Tax Act, income earned in an NRE Account is exempt from taxation. Considering the assessee's explanation supported by bank statements, the court found no justification for issuing a notice u/s 148 or passing an order u/s 148A(d) of the Act regarding the reopening of assessment.
The case pertains to the reopening of assessment u/s 147 regarding income related to a Non-Resident External (NRE) Account. The assessee argued that the source of income and deposits were from the NRE Account, and therefore, not taxable in India. The bank details and statements provided by the assessee revealed that the remittance of the loan was made from the NRE Account, substantiating the source of income. As per Section 10(4)(ii) of the Income Tax Act, income earned in an NRE Account is exempt from taxation. Considering the assessee's explanation supported by bank statements, the court found no justification for issuing a notice u/s 148 or passing an order u/s 148A(d) of the Act regarding the reopening of assessment.
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