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 allowed the assessee's appeal, rejecting the Assessing Officer's (AO) arbitrary estimation of gross profit. The tribunal found no material defects in the books of accounts, no evidence of sales suppression, and no new land purchases. The AO's rejection of accounts solely based on lower gross profit compared to previous years was deemed incorrect. Without comparable industry data or market survey to justify the 9.94% gross profit estimation, the tribunal concluded that the addition to income was unwarranted. The decision was consistent with prior scrutiny assessments where the assessee's returned income was accepted with minimal adjustments.
ITAT allowed the assessee's appeal, rejecting the Assessing Officer's (AO) arbitrary estimation of gross profit. The tribunal found no material defects in the books of accounts, no evidence of sales suppression, and no new land purchases. The AO's rejection of accounts solely based on lower gross profit compared to previous years was deemed incorrect. Without comparable industry data or market survey to justify the 9.94% gross profit estimation, the tribunal concluded that the addition to income was unwarranted. The decision was consistent with prior scrutiny assessments where the assessee's returned income was accepted with minimal adjustments.
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