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...
Additions for unexplained money failed where the Revenue relied on presumption without independent corroboration. For the alleged cash payment to or on behalf of Ms. Jwala Gutta, the Tribunal found that the seized material did not establish that the assessee himself made any cash payment, and there was no confirmation from Ms. Gutta or other supporting evidence; the addition was deleted. For the alleged cash component of marriage expenses, the Assessing Officer made no enquiry from the recipient and did not properly examine the possibility of funding from Shagun receipts, so the addition was also deleted. The Tribunal treated both additions as unsupported by evidence and allowed the appeal, with the same view applied to the other assessment years.
Additions for unexplained money failed where the Revenue relied on presumption without independent corroboration. For the alleged cash payment to or on behalf of Ms. Jwala Gutta, the Tribunal found that the seized material did not establish that the assessee himself made any cash payment, and there was no confirmation from Ms. Gutta or other supporting evidence; the addition was deleted. For the alleged cash component of marriage expenses, the Assessing Officer made no enquiry from the recipient and did not properly examine the possibility of funding from Shagun receipts, so the addition was also deleted. The Tribunal treated both additions as unsupported by evidence and allowed the appeal, with the same view applied to the other assessment years.
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