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...
Penalty under section 271(1)(c) could not be sustained where society charges and depreciation were disallowed only for want of supporting evidence or by following earlier years, because the claims were fully disclosed in the books and return and no false or inaccurate particulars were found. In an unabated year, additions under section 153C could not rest on routine disallowances without incriminating material. The Tribunal upheld deletion of the penalty, and the Revenue's challenge failed.
Penalty under section 271(1)(c) could not be sustained where society charges and depreciation were disallowed only for want of supporting evidence or by following earlier years, because the claims were fully disclosed in the books and return and no false or inaccurate particulars were found. In an unabated year, additions under section 153C could not rest on routine disallowances without incriminating material. The Tribunal upheld deletion of the penalty, and the Revenue's challenge failed.
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