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 cash deposits supported by recorded cash sales could not be treated as unexplained cash credit where the assessee produced purchase and sales registers, no specific discrepancy was found in sales, purchases or cash book, and the books were not rejected; absence of a stock register alone was insufficient, so the section 68 addition on that account was deleted. For the claimed capital introduction based on an alleged gift, the appellate relief was unsustainable because the new material was not properly tested through due process, including verification of the donor's identity, genuineness and creditworthiness; that issue was set aside and remanded to the AO for de novo adjudication.
ITAT held that cash deposits supported by recorded cash sales could not be treated as unexplained cash credit where the assessee produced purchase and sales registers, no specific discrepancy was found in sales, purchases or cash book, and the books were not rejected; absence of a stock register alone was insufficient, so the section 68 addition on that account was deleted. For the claimed capital introduction based on an alleged gift, the appellate relief was unsustainable because the new material was not properly tested through due process, including verification of the donor's identity, genuineness and creditworthiness; that issue was set aside and remanded to the AO for de novo adjudication.
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