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 dismissed Revenue's appeal regarding unexplained expenditure under section 69C. The Tribunal found that the Assessing Officer (AO) erroneously made additions based on unsubstantiated handwritten loose documents without meaningful inquiry. The seized documents lacked corroboration, contained arithmetic mistakes, and did not align with shareholders' records. The Tribunal emphasized that loose sheets are inadmissible without additional evidence under the Indian Evidence Act. The Fair Market Value calculation was deemed appropriate, considering factors like intellectual capital and future profit potential. Ultimately, the appeal was rejected, with the Tribunal concluding that the additions made during the search action were not sacrosanct or conclusive.
ITAT dismissed Revenue's appeal regarding unexplained expenditure under section 69C. The Tribunal found that the Assessing Officer (AO) erroneously made additions based on unsubstantiated handwritten loose documents without meaningful inquiry. The seized documents lacked corroboration, contained arithmetic mistakes, and did not align with shareholders' records. The Tribunal emphasized that loose sheets are inadmissible without additional evidence under the Indian Evidence Act. The Fair Market Value calculation was deemed appropriate, considering factors like intellectual capital and future profit potential. Ultimately, the appeal was rejected, with the Tribunal concluding that the additions made during the search action were not sacrosanct or conclusive.
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