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 the Revenue's appeal and upheld the order of the CIT(A) deleting additions made u/ss 68 and 69C in assessment framed u/s 153A. ITAT held that unsecured loans received by Assessee X from various companies could not be treated as bogus merely on the basis of third-party statements recorded u/s 131(1A), which were subsequently retracted, especially in absence of any incriminating material seized during search. The excel sheet found on an employee's laptop was held not to be incriminating, as all entries were duly recorded in Assessee X's books and fully corroborated by bank statements, financials, confirmations, PAN and tax records of lenders. ITAT further held that, once loans are accepted as genuine, the related addition of 1% commission u/s 69C for alleged accommodation entries also fails. All grounds raised by the Revenue were therefore rejected.
ITAT dismissed the Revenue's appeal and upheld the order of the CIT(A) deleting additions made u/ss 68 and 69C in assessment framed u/s 153A. ITAT held that unsecured loans received by Assessee X from various companies could not be treated as bogus merely on the basis of third-party statements recorded u/s 131(1A), which were subsequently retracted, especially in absence of any incriminating material seized during search. The excel sheet found on an employee's laptop was held not to be incriminating, as all entries were duly recorded in Assessee X's books and fully corroborated by bank statements, financials, confirmations, PAN and tax records of lenders. ITAT further held that, once loans are accepted as genuine, the related addition of 1% commission u/s 69C for alleged accommodation entries also fails. All grounds raised by the Revenue were therefore rejected.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4796
Join Channel
TaxTMI 
