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...
Ratification of resignation acceptance validates separation retrospectively, while withdrawal may be refused through reasoned administrative discretio...
Where seized diary and pen-drive material belonged to a third party, the rebuttable presumptions under sections 132(4A) and 292C did not apply against the assessee, so the Revenue had to produce independent corroborative evidence of actual cash receipts. As the loose sheets were not in the assessee's handwriting or signed by it, nothing was found from its premises, and the third party's retracted employee statements were not conclusive, the alleged cash receipts and the resulting profit estimation were deleted. On the alleged on-money entry, the Tribunal found no nexus between the seized material and any cash payment, and held the inference to be mere guesswork; that addition was also deleted.
Where seized diary and pen-drive material belonged to a third party, the rebuttable presumptions under sections 132(4A) and 292C did not apply against the assessee, so the Revenue had to produce independent corroborative evidence of actual cash receipts. As the loose sheets were not in the assessee's handwriting or signed by it, nothing was found from its premises, and the third party's retracted employee statements were not conclusive, the alleged cash receipts and the resulting profit estimation were deleted. On the alleged on-money entry, the Tribunal found no nexus between the seized material and any cash payment, and held the inference to be mere guesswork; that addition was also deleted.
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