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...
Transfer of outstanding family loan balances to the proprietor's capital account was treated as a mere reclassification of existing credits, because no fresh cash was introduced in the year; section 68 therefore did not apply, and the addition was deleted. The Tribunal also found no evidence that the family creditors had waived recovery, so there was no cessation of liability to trigger section 41(1). On the separate entry for TDS and self-assessment tax, the movement was only a book adjustment with no undisclosed source shown and no deduction claimed, so neither section 41(1) nor section 68 was attracted. The additions were upheld as deleted.
Transfer of outstanding family loan balances to the proprietor's capital account was treated as a mere reclassification of existing credits, because no fresh cash was introduced in the year; section 68 therefore did not apply, and the addition was deleted. The Tribunal also found no evidence that the family creditors had waived recovery, so there was no cessation of liability to trigger section 41(1). On the separate entry for TDS and self-assessment tax, the movement was only a book adjustment with no undisclosed source shown and no deduction claimed, so neither section 41(1) nor section 68 was attracted. The additions were upheld as deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4814 
Join Channel 
