The ruling emphasizes that once the Transfer Pricing Officer accepts the arm’s length nature of a transaction, the Assessing Officer cannot question its reasonableness. The disallowance was deleted as the interest rate complied with transfer pricing norms and reflected commercial reality.
The Court refused to quash criminal proceedings, holding that disputed facts cannot be decided in Section 482 jurisdiction. It allowed the applicant to seek discharge before the trial court.
The case examines whether revision under Section 263 was validly exercised. The Supreme Court upheld the High Court ruling that lack of independent application of mind invalidated the revision, reinforcing limits on PCIT powers.
The case examined whether revision under Section 263 was validly invoked. The High Court held that reliance on the Assessing Officer’s reference without independent application of mind invalidated the revision.
The case involved long-pending criminal proceedings where co-accused were acquitted due to lack of evidence. The Supreme Court indicated that excessive delay alone may justify quashing and stayed further trial proceedings.
The Tribunal held that the addition of ₹8.44 crore was unsustainable as it was based on incorrect assumptions about multiple bank accounts. It ruled that properly recorded and explained transactions cannot be treated as unexplained income under Section 69A.
The Tribunal found that the show cause notice did not identify the relevant provision under Business Auxiliary Services. It held that absence of specific legal basis renders the demand unsustainable.
The case examined whether failure to consider a binding tribunal precedent constitutes an error. The ITAT held that such non-consideration is a mistake apparent on record and recalled the issue for fresh adjudication.
The Tribunal deleted the addition after finding that cash deposits were supported by disclosed sale consideration and documentary evidence. It held that unverified objections could not override confirmed transactions.
The case examined whether scrutiny selection without meeting CBDT conditions was valid. The ITAT held that failure to satisfy mandatory criteria invalidated the notice and entire assessment.
