Revisionary jurisdiction under section 263 upheld; faceless assessments subject to revision when AO fails requisite enquiries, remitted for fresh asse...
Limited scope of processing under section 143(1): enhancement without show cause is unsustainable; remand for residency, taxation and TDS verification...
Penalty under section 271G for failure to furnish transfer pricing documentation could not survive once the underlying transfer pricing adjustment had been deleted and that deletion had been affirmed. The Tribunal held that, with the foundation of the penalty proceedings removed, there was no basis to sustain the penalty on the same transaction. The Revenue's challenge to deletion of the penalty failed, and the appellate order was upheld. The assessee's cross-objection was dismissed as infructuous because the remaining grounds had become academic.
Penalty under section 271G for failure to furnish transfer pricing documentation could not survive once the underlying transfer pricing adjustment had been deleted and that deletion had been affirmed. The Tribunal held that, with the foundation of the penalty proceedings removed, there was no basis to sustain the penalty on the same transaction. The Revenue's challenge to deletion of the penalty failed, and the appellate order was upheld. The assessee's cross-objection was dismissed as infructuous because the remaining grounds had become academic.
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