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...
Ratification of resignation acceptance validates separation retrospectively, while withdrawal may be refused through reasoned administrative discretio...
Penalty for accepting cash sale consideration under section 271D was examined in a co-owned property transaction involving an alleged contravention of section 269SS. The relevant circumstances included disclosure of the full sale consideration for taxation after receipt of cash and the absence of penalty against a co-owner participating in the same transaction. Applying the coordinate Bench approach on identical facts, the penalty was deleted. The discussion treats subsequent tax disclosure, comparable treatment of co-owners, and reasonable cause as material considerations in determining whether a cash-acceptance penalty should stand.
Penalty for accepting cash sale consideration under section 271D was examined in a co-owned property transaction involving an alleged contravention of section 269SS. The relevant circumstances included disclosure of the full sale consideration for taxation after receipt of cash and the absence of penalty against a co-owner participating in the same transaction. Applying the coordinate Bench approach on identical facts, the penalty was deleted. The discussion treats subsequent tax disclosure, comparable treatment of co-owners, and reasonable cause as material considerations in determining whether a cash-acceptance penalty should stand.
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