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 upheld deletion of disallowance of interest expenditure because the Assessing Officer failed to show any nexus between borrowed funds and non-business use, while the assessee had sufficient interest-free funds and used the borrowings for business purposes. It also sustained deletion of the section 68 addition on unsecured loans because bank statements, confirmations, income-tax records, TDS material and banking-channel transfers established genuineness. The Tribunal further rejected the purchase-difference addition, holding that purchases were recorded at actual cost and the variance from TCS figures arose from rebates, discounts and instances where TCS was not collected. The Revenue's appeal was dismissed in full.
ITAT upheld deletion of disallowance of interest expenditure because the Assessing Officer failed to show any nexus between borrowed funds and non-business use, while the assessee had sufficient interest-free funds and used the borrowings for business purposes. It also sustained deletion of the section 68 addition on unsecured loans because bank statements, confirmations, income-tax records, TDS material and banking-channel transfers established genuineness. The Tribunal further rejected the purchase-difference addition, holding that purchases were recorded at actual cost and the variance from TCS figures arose from rebates, discounts and instances where TCS was not collected. The Revenue's appeal was dismissed in full.
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