Home Highlights June 2013 Year 2013 This

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1. 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...

2. 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...

3. 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...

4. 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...

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

6. 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...

7. 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...

8. Accrual of income - Addition made to the income of the assessee received by the assessee from “JDS” and its associates, treated as own income of the assessee - Despite...

9. Protective assessment - Addition in the hands of the Assessee Firm on protective basis - since the substantive addition has not been survived on account of being time...

10. Unexplained cash credit u/s.68 - authenticity of the credits - as the assessee had in the course of proceedings before the lower authorities adopted an evasive approach...

11. Estimation of net profit - rejection of books of accounts - Once the books of account of the assessee was produced before the lower authorities and if there is certain...

12. Method of valuation of shares - Addition u/s 56(2)(viib) - The lower authorities have not examined the basis on which the valuation is done and from the perusal of...

13. 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...

14. TP adjustment - Enhanced deduction u/s.10A - as per Section 92C(4) of the Act, TP addition has to be separately done, whatever may be the addition in respect of other...

15. TP Adjustment - TPO rejected the TP study undertaken by the assessee and proceeded to apply TNMM at the entity level which the assessee company has objected to - CIT(A)...