Pure-agent exclusion fails where hotel booking facilitators receive third-party services themselves, making entire customer consideration taxable as r...
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...
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Penalty for furnishing inaccurate particulars cannot survive where it rests solely on a bad-debt disallowance that has been deleted. Once the Tribunal deleted the quantum addition and the High Court confirmed that deletion, no tax liability remained in respect of the disallowance. The consequential penalty for concealment or furnishing inaccurate particulars was therefore deleted, with the Tribunal's deletion sustained and the revenue's appeal dismissed.
Penalty for furnishing inaccurate particulars cannot survive where it rests solely on a bad-debt disallowance that has been deleted. Once the Tribunal deleted the quantum addition and the High Court confirmed that deletion, no tax liability remained in respect of the disallowance. The consequential penalty for concealment or furnishing inaccurate particulars was therefore deleted, with the Tribunal's deletion sustained and the revenue's appeal dismissed.
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