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 addressed taxation of income declared on excess stock found during survey, applying the principle that surrendered income arising from the same business activities must be taxed as business income rather than treated as undisclosed investment; outcome: CIT(A)'s direction to treat the surrender as regular business income is upheld. On disallowance of expenses for lack of documentary support, AO's additions were restored because vouchers were treated as self-made and expenses paid in cash. Claims for twice-booked meal expenses were disallowed and CIT(A)'s partial relief set aside. Vehicle expenditure disallowance based on absence of logbook/support was also restored to the AO's higher disallowance.
ITAT addressed taxation of income declared on excess stock found during survey, applying the principle that surrendered income arising from the same business activities must be taxed as business income rather than treated as undisclosed investment; outcome: CIT(A)'s direction to treat the surrender as regular business income is upheld. On disallowance of expenses for lack of documentary support, AO's additions were restored because vouchers were treated as self-made and expenses paid in cash. Claims for twice-booked meal expenses were disallowed and CIT(A)'s partial relief set aside. Vehicle expenditure disallowance based on absence of logbook/support was also restored to the AO's higher disallowance.
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