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...
Section 194N places the obligation to deduct tax at source on the banking company making a cash payment, not on the customer withdrawing cash. Failure to deduct attracts the statutory consequence under section 271C against the person responsible for deduction. A bank cannot impose a lien on a customer's current account for an alleged TDS liability without statutory authority or a direction from the income-tax authorities. The lien was directed to be released and account operations permitted after the customer furnished income-tax returns for the relevant three consecutive years, without limiting lawful action by tax authorities.
Section 194N places the obligation to deduct tax at source on the banking company making a cash payment, not on the customer withdrawing cash. Failure to deduct attracts the statutory consequence under section 271C against the person responsible for deduction. A bank cannot impose a lien on a customer's current account for an alleged TDS liability without statutory authority or a direction from the income-tax authorities. The lien was directed to be released and account operations permitted after the customer furnished income-tax returns for the relevant three consecutive years, without limiting lawful action by tax authorities.
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