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...
ITAT upheld addition under section 68 regarding unexplained cash deposits of Rs. 78,00,000/- as assessee failed to provide satisfactory explanation or supporting documentation despite opportunities from AO and CIT(A). Assessee's alternative plea to apply 8% presumptive taxation under section 44AD was rejected as turnover exceeded eligible threshold of Rs. 60 lakh. However, ITAT deleted AO's addition of 8% presumptive tax on remaining turnover of Rs. 28,14,676/-, accepting explanation that deposits originated from assessee's business profits and father's savings/business accruals. Tribunal found father's business history with turnover between Rs. 51-62 lakh made explanation plausible. Appeal partially allowed with respect to smaller cash deposits while maintaining primary addition under section 68.
ITAT upheld addition under section 68 regarding unexplained cash deposits of Rs. 78,00,000/- as assessee failed to provide satisfactory explanation or supporting documentation despite opportunities from AO and CIT(A). Assessee's alternative plea to apply 8% presumptive taxation under section 44AD was rejected as turnover exceeded eligible threshold of Rs. 60 lakh. However, ITAT deleted AO's addition of 8% presumptive tax on remaining turnover of Rs. 28,14,676/-, accepting explanation that deposits originated from assessee's business profits and father's savings/business accruals. Tribunal found father's business history with turnover between Rs. 51-62 lakh made explanation plausible. Appeal partially allowed with respect to smaller cash deposits while maintaining primary addition under section 68.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4798
Join Channel
TaxTMI 
