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: where an assessee opts to declare income under the presumptive scheme and offers income accordingly, separate additions for unexplained cash bank deposits cannot be sustained; the tribunal relied on precedent holding that opting into the presumptive regime removes the obligation to explain each cash entry, and directed deletion of the addition. The appellate authority allowed the assessee's appeal and set aside the lower appellate order that had limited relief to bank debits, restoring complete relief against the addition by the assessing officer.
Presumptive taxation: where an assessee opts to declare income under the presumptive scheme and offers income accordingly, separate additions for unexplained cash bank deposits cannot be sustained; the tribunal relied on precedent holding that opting into the presumptive regime removes the obligation to explain each cash entry, and directed deletion of the addition. The appellate authority allowed the assessee's appeal and set aside the lower appellate order that had limited relief to bank debits, restoring complete relief against the addition by the assessing officer.
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