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...
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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...
Addition of fixed deposits and interest thereon in wife's name was deleted as the Revenue could not controvert that the deposits belonged to the assessee's wife from her marriage gift. Addition of silverware weighing 33 kgs was deleted as the assessee's wife owned these assets gifted by her father. Estimated marriage expenses were restricted to Rs. 3 lakhs instead of Rs. 5 lakhs estimated by AO. Personal drawings addition was limited to Rs. 2.7 lakhs for rental payments instead of Rs. 8.05 lakhs estimated by AO. Advance tax payments of Rs. 1.3 lakhs, foreign trip expenses, and bank deposits additions were upheld. Investment of Rs. 3 lakhs in Himalaya Benefit Fund and consequential interest of Rs. 4.77 lakhs were confirmed as undisclosed income. Additions based on materials from Enforcement Directorate regarding transponder hire charges of Rs. 2.24 crores, transponder hire facility payments, purchase of equipment abroad and Malaysian Ringgits were deleted as relatable to the company.
Addition of fixed deposits and interest thereon in wife's name was deleted as the Revenue could not controvert that the deposits belonged to the assessee's wife from her marriage gift. Addition of silverware weighing 33 kgs was deleted as the assessee's wife owned these assets gifted by her father. Estimated marriage expenses were restricted to Rs. 3 lakhs instead of Rs. 5 lakhs estimated by AO. Personal drawings addition was limited to Rs. 2.7 lakhs for rental payments instead of Rs. 8.05 lakhs estimated by AO. Advance tax payments of Rs. 1.3 lakhs, foreign trip expenses, and bank deposits additions were upheld. Investment of Rs. 3 lakhs in Himalaya Benefit Fund and consequential interest of Rs. 4.77 lakhs were confirmed as undisclosed income. Additions based on materials from Enforcement Directorate regarding transponder hire charges of Rs. 2.24 crores, transponder hire facility payments, purchase of equipment abroad and Malaysian Ringgits were deleted as relatable to the company.
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