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...
Where reopening is founded on material seized in a third-party search, section 153C operates as the special procedure for assessment of that other person and overrides general reassessment under section 147; the reassessment was therefore void ab initio and the annulment was upheld. On merits, additions for alleged cash loans and interest based only on a retracted survey statement could not stand because no independent corroborative evidence was produced and the seized broker documents did not implicate the assessee. The Tribunal accordingly dismissed the Revenue's challenge and sustained the finding that the additions were unsustainable.
Where reopening is founded on material seized in a third-party search, section 153C operates as the special procedure for assessment of that other person and overrides general reassessment under section 147; the reassessment was therefore void ab initio and the annulment was upheld. On merits, additions for alleged cash loans and interest based only on a retracted survey statement could not stand because no independent corroborative evidence was produced and the seized broker documents did not implicate the assessee. The Tribunal accordingly dismissed the Revenue's challenge and sustained the finding that the additions were unsustainable.
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