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...
An unsigned notice initiating penalty proceedings under section 274 read with section 271(1)(c) was held invalid because section 282A requires statutory notices to be signed. Printing the authority's name, office, or a DIN did not satisfy that mandatory requirement, and the defect was treated as jurisdictional rather than technical. The assessee's participation and section 292B could not cure the absence of signature, and a later signed reminder notice did not validate the original initiation. As the Assessing Officer never acquired valid jurisdiction to proceed, the consequential reminder notice and penalty order were quashed.
An unsigned notice initiating penalty proceedings under section 274 read with section 271(1)(c) was held invalid because section 282A requires statutory notices to be signed. Printing the authority's name, office, or a DIN did not satisfy that mandatory requirement, and the defect was treated as jurisdictional rather than technical. The assessee's participation and section 292B could not cure the absence of signature, and a later signed reminder notice did not validate the original initiation. As the Assessing Officer never acquired valid jurisdiction to proceed, the consequential reminder notice and penalty order were quashed.
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