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...
A false refund claim in an income-tax return, supported by fabricated housing-loan documents, attracted prosecution under Section 277. The evidence of the complainant and bank officer proved that the claimed loan documents were false and that no housing loan existed in the taxpayer's name. Once the false statement in the return was established, Section 278E required a presumption of culpable mental state, which was not rebutted because no defence evidence was led and the explanation to the notice was rejected. The concurrent findings were found free from legal infirmity, so the conviction, sentence, and revision dismissal were upheld.
A false refund claim in an income-tax return, supported by fabricated housing-loan documents, attracted prosecution under Section 277. The evidence of the complainant and bank officer proved that the claimed loan documents were false and that no housing loan existed in the taxpayer's name. Once the false statement in the return was established, Section 278E required a presumption of culpable mental state, which was not rebutted because no defence evidence was led and the explanation to the notice was rejected. The concurrent findings were found free from legal infirmity, so the conviction, sentence, and revision dismissal were upheld.
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