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...
WhatsApp messages used to support an alleged cash transaction were held insufficient without corroboration, so the related addition was deleted. Additions based on a retracted search statement and a third-party statement were also unsustainable where the assessee sought copies of material and cross-examination, but no proper evidentiary foundation or independent enquiry was made. Income already returned and taxed in the spouse's hands could not be taxed again as the assessee's undisclosed income. For agricultural income, the Tribunal accepted documentary support and upheld only a limited estimate rather than the full addition. Additions based on presumed agricultural income of family members were likewise rejected for want of evidence.
WhatsApp messages used to support an alleged cash transaction were held insufficient without corroboration, so the related addition was deleted. Additions based on a retracted search statement and a third-party statement were also unsustainable where the assessee sought copies of material and cross-examination, but no proper evidentiary foundation or independent enquiry was made. Income already returned and taxed in the spouse's hands could not be taxed again as the assessee's undisclosed income. For agricultural income, the Tribunal accepted documentary support and upheld only a limited estimate rather than the full addition. Additions based on presumed agricultural income of family members were likewise rejected for want of evidence.
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