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 once the source of cash is taxed, it cannot be further taxed as unexplained cash expenditure in the hands of the assessee company. The assessee had furnished details regarding the source of cash expenditures which were accepted by the Interim Board for Settlement. The addition made u/s 69C for cash payments treated as unexplained expenditure by the Assessing Officer was deleted, as it would amount to double taxation, since the cash income was already offered to tax in the hands of the Director. The issue was decided in favour of the assessee.
The ITAT held that once the source of cash is taxed, it cannot be further taxed as unexplained cash expenditure in the hands of the assessee company. The assessee had furnished details regarding the source of cash expenditures which were accepted by the Interim Board for Settlement. The addition made u/s 69C for cash payments treated as unexplained expenditure by the Assessing Officer was deleted, as it would amount to double taxation, since the cash income was already offered to tax in the hands of the Director. The issue was decided in favour of the assessee.
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