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...
Presumptive taxation under section 44AD was applied to estimate net profit where the assessee failed to file returns or participate in assessment proceedings; the AO had applied an 18% net profit rate based on TDS under section 194C, but the Tribunal considered the lack of participation and limited evidence and reduced the presumptive net profit rate to 8%, computing the assessee's income accordingly and deleting the remaining additions. Grounds of appeal were partly allowed.
Presumptive taxation under section 44AD was applied to estimate net profit where the assessee failed to file returns or participate in assessment proceedings; the AO had applied an 18% net profit rate based on TDS under section 194C, but the Tribunal considered the lack of participation and limited evidence and reduced the presumptive net profit rate to 8%, computing the assessee's income accordingly and deleting the remaining additions. Grounds of appeal were partly allowed.
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