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 affirmed re-assessment notice for AY 2013-14 as valid under TOLA, finding no procedural objections by the assessee. On unexplained bank deposits, the tribunal determined a taxable profit margin of 8% rather than the assessee's proposed 3-7% range, lacking substantive evidence. The tribunal directed the Assessing Officer to separately compute business income and interest income, with TDS on interest to be brought to tax under income from other sources. The appeal was partly allowed, with the re-assessment proceedings upheld and a modified approach to taxing unexplained deposits implemented.
ITAT affirmed re-assessment notice for AY 2013-14 as valid under TOLA, finding no procedural objections by the assessee. On unexplained bank deposits, the tribunal determined a taxable profit margin of 8% rather than the assessee's proposed 3-7% range, lacking substantive evidence. The tribunal directed the Assessing Officer to separately compute business income and interest income, with TDS on interest to be brought to tax under income from other sources. The appeal was partly allowed, with the re-assessment proceedings upheld and a modified approach to taxing unexplained deposits implemented.
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