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 inaccurate particulars in professional-fee claims requires substantiated expenditure and independent findings supporting concealment or inaccurate particulars. A payment characterised as professional fees but shown to be a loan advanced and repaid, with a corresponding receipt credited to profit and loss, is revenue neutral and does not support disallowance or penalty. Conversely, penalty remains justified where claimed payees deny receipt or payments remain unsubstantiated. Liability to deduct tax on professional fees depends on satisfying the statutory threshold based on gross receipts in the immediately preceding financial year; older receipt data alone is insufficient. Disallowance for non-deduction of tax does not, by itself, justify penalty.
Penalty for inaccurate particulars in professional-fee claims requires substantiated expenditure and independent findings supporting concealment or inaccurate particulars. A payment characterised as professional fees but shown to be a loan advanced and repaid, with a corresponding receipt credited to profit and loss, is revenue neutral and does not support disallowance or penalty. Conversely, penalty remains justified where claimed payees deny receipt or payments remain unsubstantiated. Liability to deduct tax on professional fees depends on satisfying the statutory threshold based on gross receipts in the immediately preceding financial year; older receipt data alone is insufficient. Disallowance for non-deduction of tax does not, by itself, justify penalty.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4816 
Join Channel 
