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 a reasonable gross profit rate of 2% should be applied on unaccounted purchases of gold, instead of the AO's net profit rate of 12%. The disallowance u/s 40A(3) was deleted as the income was assessed applying the flat gross profit rate. The addition for excess stock jewellery was set aside and remanded to the AO for fresh adjudication after verifying the invoices filed by the assessee.
The ITAT held that a reasonable gross profit rate of 2% should be applied on unaccounted purchases of gold, instead of the AO's net profit rate of 12%. The disallowance u/s 40A(3) was deleted as the income was assessed applying the flat gross profit rate. The addition for excess stock jewellery was set aside and remanded to the AO for fresh adjudication after verifying the invoices filed by the assessee.
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