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 partially allowed the appeal, reducing the estimated income addition from 10% to 1.52% of declared turnover. Despite concerns about unaudited accounts and non-filing of returns, the tribunal recognized the assessee's self-declared figures and permitted a set-off of Rs. 1,49,165/-. The decision mandates the assessee to reconcile financial discrepancies while moderating the income addition imposed by the Assessing Officer, thereby striking a balance between procedural compliance and equitable tax assessment.
ITAT partially allowed the appeal, reducing the estimated income addition from 10% to 1.52% of declared turnover. Despite concerns about unaudited accounts and non-filing of returns, the tribunal recognized the assessee's self-declared figures and permitted a set-off of Rs. 1,49,165/-. The decision mandates the assessee to reconcile financial discrepancies while moderating the income addition imposed by the Assessing Officer, thereby striking a balance between procedural compliance and equitable tax assessment.
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