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 acceptance of cash loans was held unsustainable where the assessment order under section 143(3) accepted the returned income but did not record satisfaction for initiating proceedings under section 271D. Applying the principle in Jai Laxmi Rice Mills, the Tribunal treated the absence of recorded satisfaction in the assessment order as fatal to penalty initiation and directed deletion of the penalty.
Penalty for acceptance of cash loans was held unsustainable where the assessment order under section 143(3) accepted the returned income but did not record satisfaction for initiating proceedings under section 271D. Applying the principle in Jai Laxmi Rice Mills, the Tribunal treated the absence of recorded satisfaction in the assessment order as fatal to penalty initiation and directed deletion of the penalty.
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