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 misreporting under section 270A requires the assessing authority to identify the precise limb in section 270A(9) and explain how the additions satisfy that clause. A mere ad hoc disallowance of labour or loading and unloading charges, or a disallowance based on alleged non-deduction of tax at source, does not by itself establish misreporting of income. The text also notes that email-only appellate notices, when the assessee had opted for another mode, do not justify an adverse inference from non-appearance. On that reasoning, the penalty was deleted.
Penalty for misreporting under section 270A requires the assessing authority to identify the precise limb in section 270A(9) and explain how the additions satisfy that clause. A mere ad hoc disallowance of labour or loading and unloading charges, or a disallowance based on alleged non-deduction of tax at source, does not by itself establish misreporting of income. The text also notes that email-only appellate notices, when the assessee had opted for another mode, do not justify an adverse inference from non-appearance. On that reasoning, the penalty was deleted.
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