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...
Waiver of penalty u/s 78 was allowed but waiver of penalty u/s 76 was refused by the tribunal - once the assessee proves that there was reasonable cause for the failure. Section 80 starts to operate, insulating the imposition of any other penalties under Section 76, Section 77 or Section 78 of the Act. Insofar as the appellant is concerned, this is inexcusably applicable in law - HC
Waiver of penalty u/s 78 was allowed but waiver of penalty u/s 76 was refused by the tribunal - once the assessee proves that there was reasonable cause for the failure. Section 80 starts to operate, insulating the imposition of any other penalties under Section 76, Section 77 or Section 78 of the Act. Insofar as the appellant is concerned, this is inexcusably applicable in law - HC
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