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...
Telescoping was applied to undisclosed on-money receipts against cash deposits made during demonetisation, but only 50% relief was granted because no corresponding physical cash was found and the assessee could not fully explain that aspect. The surviving addition was held not chargeable under section 115BBE for the year in question, and had to be taxed under the normal provisions. Receipts described as advances from customers and a loan receipt were treated as business turnover already covered by the telescoping of on-money and were deleted as separate section 68 additions. An addition relating to a creditor was also deleted because the assessee had discharged the initial onus with documents and the creditor had been examined without adverse findings.
Telescoping was applied to undisclosed on-money receipts against cash deposits made during demonetisation, but only 50% relief was granted because no corresponding physical cash was found and the assessee could not fully explain that aspect. The surviving addition was held not chargeable under section 115BBE for the year in question, and had to be taxed under the normal provisions. Receipts described as advances from customers and a loan receipt were treated as business turnover already covered by the telescoping of on-money and were deleted as separate section 68 additions. An addition relating to a creditor was also deleted because the assessee had discharged the initial onus with documents and the creditor had been examined without adverse findings.
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