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 Appellate Tribunal allowed the assessee's appeal against the invocation of Section 263 by the Principal Commissioner of Income Tax (PCIT) for disallowing the entire purchases of Rs. 102,43,73,377/-. The Tribunal held that the Assessing Officer (AO) had reasonably disallowed only 10% of the purchases after duly considering the details furnished by the assessee during the assessment proceedings u/s 143(3). The PCIT's action of proposing to disallow the entire purchases against the basic principle of business, without appreciating that the assessee had achieved a turnover of Rs. 132,12,33,622/-, was erroneous. The Tribunal ruled that the AO's order cannot be termed erroneous to invoke Section 263, as it is not every error that should induce the PCIT to exercise powers under that section, especially when the AO has considered the issue carefully and cautiously.
The Appellate Tribunal allowed the assessee's appeal against the invocation of Section 263 by the Principal Commissioner of Income Tax (PCIT) for disallowing the entire purchases of Rs. 102,43,73,377/-. The Tribunal held that the Assessing Officer (AO) had reasonably disallowed only 10% of the purchases after duly considering the details furnished by the assessee during the assessment proceedings u/s 143(3). The PCIT's action of proposing to disallow the entire purchases against the basic principle of business, without appreciating that the assessee had achieved a turnover of Rs. 132,12,33,622/-, was erroneous. The Tribunal ruled that the AO's order cannot be termed erroneous to invoke Section 263, as it is not every error that should induce the PCIT to exercise powers under that section, especially when the AO has considered the issue carefully and cautiously.
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