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...
Issue of benami property transactions and the appellant's failure to prove the source of income for acquiring properties worth Rs. 1,41,37,500/-. The Initiating Officer alleged that the appellant, an employee with a meagre salary, acquired benami properties. The Adjudicating Authority found that the appellant could not produce documents to substantiate the source of income for purchasing the properties. The appellant tried to rely on an income tax assessment order, but the Tribunal held that it cannot be used for adjudication under the Benami Transactions Act. The Adjudicating Authority's detailed findings revealed the benami nature of the properties acquired largely in cash without disclosing the source. The appellant failed to submit material proving the source of income before the authorities. The Tribunal dismissed the appeal, finding no favorable material for the appellant, and rejected the reliance on the Supreme Court's recalled judgment in Ganpati Dealcom case.
Issue of benami property transactions and the appellant's failure to prove the source of income for acquiring properties worth Rs. 1,41,37,500/-. The Initiating Officer alleged that the appellant, an employee with a meagre salary, acquired benami properties. The Adjudicating Authority found that the appellant could not produce documents to substantiate the source of income for purchasing the properties. The appellant tried to rely on an income tax assessment order, but the Tribunal held that it cannot be used for adjudication under the Benami Transactions Act. The Adjudicating Authority's detailed findings revealed the benami nature of the properties acquired largely in cash without disclosing the source. The appellant failed to submit material proving the source of income before the authorities. The Tribunal dismissed the appeal, finding no favorable material for the appellant, and rejected the reliance on the Supreme Court's recalled judgment in Ganpati Dealcom case.
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