Home Highlights June 2013 Year 2013 This

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1. Transfer pricing adjustment on international transaction involving payment of guarantee fees to associated enterprise was held unjustified. Assessee demonstrated...

2. The assessment reopening u/s 147 read with Section 148 was found to be unsustainable due to the lack of independent application of mind by the Commissioner of Income Tax...

3. In the case of 2024 (5) TMI 1097 before the ITAT Kolkata, the issue revolved around the addition made u/s 50C of the Income Tax Act. The assessee had contended that the...

4. Addition of deemed income u/s 56(2)(vii)(b) - difference in purchase price and stamps authority valuation - Addition made by lower-authorities is mandated by section...

5. Re-determinination of value of opening stock - Addition of excess stock found during the course of survey - Once additions is made towards excess stock found during the...

6. Additions towards Bogus purchases - Estimation of profit - Purchases are to be removed, the corresponding sale is also required to be removed from the profit and loss...

7. Classification of goods - Kalva raksha sutra - the ruling do not delve on what makes a kalava and how the product is not a ‘kalava’. In as much as the issue raised...

8. Penalty u/s 271(c) was imposed on additions of 25% of non-verifiable purchases debited to the trading account. The addition was made on estimation of total turnover...

9. TP Adjustment - AMP adjustment - Assessee has already been remunerated for the marketing expenses incurred on behalf of the AEs along with commission markup, and,...

10. Imposition of penalty u/s 271(1)(c) of the Income Tax Act for two types of additions: (1) the addition made u/s 50C on the difference between stamp duty value and sale...

11. TP Adjustment - CIT(A) under the garb of "rule of consistency" adopted the TP analysis made by the TPO - This method of TP analysis is unheard of as every assessment...

12. TP Adjustment - AMP expenses by applying bright line test on protective basis - TP adjustment amounting by applying BLT is not sustainable on protective basis having no...

13. Transfer pricing officer (TPO) erred by considering non-associated enterprise (non-AE) revenue and costs while computing transfer pricing (TP) adjustment, contrary to...

14. Addition on the basis of declaration made by assessee during a search action u/s 132 - The ITAT found no merit in the revenue's arguments, noting that the addition was...

15. Evidentiary value of a statement made on oath by the assessee for making additions - The assessee can explain or withdraw the admission, if any, made by him in such...