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 notices under section 270A must specify whether the proposed charge is under-reporting of income or misreporting under a particular statutory limb. Notices that omit the precise charge fail to communicate the basis of penalty proceedings and are contrary to law. Applying this requirement, the Tribunal quashed the penalty proceedings for both assessment years and deleted the penalties because the notices did not identify the applicable charge.
Penalty notices under section 270A must specify whether the proposed charge is under-reporting of income or misreporting under a particular statutory limb. Notices that omit the precise charge fail to communicate the basis of penalty proceedings and are contrary to law. Applying this requirement, the Tribunal quashed the penalty proceedings for both assessment years and deleted the penalties because the notices did not identify the applicable charge.
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