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 for failure to comply with statutory notices under section 142(1) was held unsustainable where the assessee proved reasonable cause under section 273B. The Tribunal accepted the explanation that non-compliance arose from a medical condition and was not deliberate or intentional, so the protective exception applied and penalty under section 272A(1)(d) was deleted.
Penalty for failure to comply with statutory notices under section 142(1) was held unsustainable where the assessee proved reasonable cause under section 273B. The Tribunal accepted the explanation that non-compliance arose from a medical condition and was not deliberate or intentional, so the protective exception applied and penalty under section 272A(1)(d) was deleted.
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