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 ITAT held that: The assessee was entitled to claim deduction for interest expenses incurred in relation to interest-free loans granted to wholly owned subsidiaries operating in the same line of business, as the loans were for commercial expediency. The cash deposits were made in the normal course of the assessee's restaurant/hospitality business, and the addition u/s 68 was deleted. Regarding rental income receipts, the issue was set aside for denovo adjudication by the AO after necessary inquiries/verification, as the room and food/banquet income was included under "Revenue from Operations" in the P&L account, and details of TDS and rent earned were not disputed.
The ITAT held that: The assessee was entitled to claim deduction for interest expenses incurred in relation to interest-free loans granted to wholly owned subsidiaries operating in the same line of business, as the loans were for commercial expediency. The cash deposits were made in the normal course of the assessee's restaurant/hospitality business, and the addition u/s 68 was deleted. Regarding rental income receipts, the issue was set aside for denovo adjudication by the AO after necessary inquiries/verification, as the room and food/banquet income was included under "Revenue from Operations" in the P&L account, and details of TDS and rent earned were not disputed.
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