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 held that the plea of denial of opportunity in assessment was factually untenable because statutory notices were issued, replies were filed, and the assessee had not raised the grievance before the first appellate authority. It further held that the dispute concerned only the year of taxability of contractual receipts, which depended on the accounting method actually followed. As the assessee failed to substantiate the claimed completed service contract method, had received the amounts in the relevant year, and the receipts were reflected in Form 26AS with tax deduction, the additions were sustained and the receipts were taxable in Assessment Year 2018-19.
ITAT held that the plea of denial of opportunity in assessment was factually untenable because statutory notices were issued, replies were filed, and the assessee had not raised the grievance before the first appellate authority. It further held that the dispute concerned only the year of taxability of contractual receipts, which depended on the accounting method actually followed. As the assessee failed to substantiate the claimed completed service contract method, had received the amounts in the relevant year, and the receipts were reflected in Form 26AS with tax deduction, the additions were sustained and the receipts were taxable in Assessment Year 2018-19.
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