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 held that an assessment selected for limited scrutiny on cash deposits could not be widened to examine other bank credits or treat them as business receipts without the mandatory administrative approval and intimation required under CBDT instructions. Because the AO went beyond the flagged issue without jurisdiction, the assessment was set aside. On merits, amounts transferred by partners from their own bank accounts and reflected in their capital accounts were accepted as partners' deposits, not the firm's business income, since the partners had disclosed those sums in their individual returns and no material showed that the receipts belonged to the firm.
ITAT held that an assessment selected for limited scrutiny on cash deposits could not be widened to examine other bank credits or treat them as business receipts without the mandatory administrative approval and intimation required under CBDT instructions. Because the AO went beyond the flagged issue without jurisdiction, the assessment was set aside. On merits, amounts transferred by partners from their own bank accounts and reflected in their capital accounts were accepted as partners' deposits, not the firm's business income, since the partners had disclosed those sums in their individual returns and no material showed that the receipts belonged to the firm.
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