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 furnish a tax audit report was deleted where consistent past and subsequent treatment of bank interest as income from other sources supported a bona fide belief that the audit requirement was not attracted. The assessee had disclosed the interest uniformly in earlier and later years, and that treatment had been accepted in section 143(1) intimations. As the Revenue produced no material of deliberate or conscious default, the failure was treated as covered by reasonable cause, making the penalty unsustainable.
Penalty for failure to furnish a tax audit report was deleted where consistent past and subsequent treatment of bank interest as income from other sources supported a bona fide belief that the audit requirement was not attracted. The assessee had disclosed the interest uniformly in earlier and later years, and that treatment had been accepted in section 143(1) intimations. As the Revenue produced no material of deliberate or conscious default, the failure was treated as covered by reasonable cause, making the penalty unsustainable.
Note: It is a system-generated summary and is for quick reference only.