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 adjudicated a tax dispute involving circular trading and salary expenses. The tribunal found no substantive evidence to support the Assessing Officer's (AO) arbitrary addition of commission income. The AO's estimate of 3% on sales and purchases was deemed unwarranted, as no specific allegation of commission payment was established in KGR Enterprises' assessment order. Similarly, the adhoc addition under salary and wages was deleted, as the expenses were commensurate with business turnover and no specific defects were identified in the documentation. The tribunal ultimately rejected both proposed additions, providing relief to the assessee by eliminating the unsupported tax adjustments.
ITAT adjudicated a tax dispute involving circular trading and salary expenses. The tribunal found no substantive evidence to support the Assessing Officer's (AO) arbitrary addition of commission income. The AO's estimate of 3% on sales and purchases was deemed unwarranted, as no specific allegation of commission payment was established in KGR Enterprises' assessment order. Similarly, the adhoc addition under salary and wages was deleted, as the expenses were commensurate with business turnover and no specific defects were identified in the documentation. The tribunal ultimately rejected both proposed additions, providing relief to the assessee by eliminating the unsupported tax adjustments.
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