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 assessee claimed the entire cash amount recovered from two lockers as business income, not subject to tax u/s 115BBE. The Tribunal held that since the cash from one locker was recorded in books and the source of income from the other locker was not disputed, both amounts should be treated as business income under normal provisions, not taxed u/s 69A read with Section 115BBE dealing with unexplained cash credits. The application of Section 115BBE was found to be not legal in this case.
The assessee claimed the entire cash amount recovered from two lockers as business income, not subject to tax u/s 115BBE. The Tribunal held that since the cash from one locker was recorded in books and the source of income from the other locker was not disputed, both amounts should be treated as business income under normal provisions, not taxed u/s 69A read with Section 115BBE dealing with unexplained cash credits. The application of Section 115BBE was found to be not legal in this case.
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