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 under section 270A for under-reporting of income may be excluded where a bona fide computational error explains the reduction of a returned loss and all material facts were disclosed. The notes describe an inadvertent double deduction of exempt partnership-firm profit in Schedule BP, although the amount had already been disclosed in Schedule EI and reflected in the balance sheet. Acceptance of recomputation, supported by a Chartered Accountant's affidavit, and the absence of proof that the explanation was false supported deletion of the penalty. Repetition of the error in a revised return was not, by itself, treated as conclusive evidence of misreporting or inaccurate particulars.
Penalty under section 270A for under-reporting of income may be excluded where a bona fide computational error explains the reduction of a returned loss and all material facts were disclosed. The notes describe an inadvertent double deduction of exempt partnership-firm profit in Schedule BP, although the amount had already been disclosed in Schedule EI and reflected in the balance sheet. Acceptance of recomputation, supported by a Chartered Accountant's affidavit, and the absence of proof that the explanation was false supported deletion of the penalty. Repetition of the error in a revised return was not, by itself, treated as conclusive evidence of misreporting or inaccurate particulars.
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