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...
A penalty notice under section 270A must specify the precise limb of charge to be valid; a notice that fails to disclose whether the penalty is proposed for the applicable specific default is vague and unsustainable in law. Applying this principle, the Tribunal held that the notice was void ab initio because it did not mention the particular limb under which penalty was initiated, and the consequential penalty order was also liable to be quashed.
A penalty notice under section 270A must specify the precise limb of charge to be valid; a notice that fails to disclose whether the penalty is proposed for the applicable specific default is vague and unsustainable in law. Applying this principle, the Tribunal held that the notice was void ab initio because it did not mention the particular limb under which penalty was initiated, and the consequential penalty order was also liable to be quashed.
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