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...
TDS credit is available only to the person in whose hands the related income is assessable. The assessee, an APMC commission agent, admitted that the purchases and sales on which tax was deducted were those of agriculturists or farmers, not his own sales income. On that factual basis, the ITAT held that TDS reflected in the assessee's PAN was a wrong deduction entry and could not be claimed by him without corresponding income being offered to tax. The proper remedy was correction of the TDS statement by the deductor or issue of the credit in the correct names. The denial of TDS credit was upheld and the appeal was dismissed.
TDS credit is available only to the person in whose hands the related income is assessable. The assessee, an APMC commission agent, admitted that the purchases and sales on which tax was deducted were those of agriculturists or farmers, not his own sales income. On that factual basis, the ITAT held that TDS reflected in the assessee's PAN was a wrong deduction entry and could not be claimed by him without corresponding income being offered to tax. The proper remedy was correction of the TDS statement by the deductor or issue of the credit in the correct names. The denial of TDS credit was upheld and the appeal was dismissed.
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