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...
Unexplained trade credits must be supported by proof of source, creditor identity and mode of payment; where these are not satisfactorily established, the receipt loses its character as business income and is taxable under Section 68 as income from other sources. The assessee must also show that the receipt is derived from the eligible industrial undertaking before claiming deduction under Sections 80-IA/80-IB. An unexplained credit not shown as business receipt cannot be linked to eligible profits or enjoy the deduction. The credits were therefore treated as taxable unexplained income, and the deduction claim failed.
Unexplained trade credits must be supported by proof of source, creditor identity and mode of payment; where these are not satisfactorily established, the receipt loses its character as business income and is taxable under Section 68 as income from other sources. The assessee must also show that the receipt is derived from the eligible industrial undertaking before claiming deduction under Sections 80-IA/80-IB. An unexplained credit not shown as business receipt cannot be linked to eligible profits or enjoy the deduction. The credits were therefore treated as taxable unexplained income, and the deduction claim failed.
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