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...
Declaration not admissible in evidence against declarant - THE INCOME DECLARATION SCHEME, 2016 - Notwithstanding anything contained in any other law for the time being in force, nothing contained in any declaration made under section 180 shall be admissible in evidence against the declarant for the purpose of any proceeding relating to imposition of penalty, other than the penalty leviable under section 182, or for the purposes of prosecution under the Income-tax Act or the Wealth-tax Act, 1957 (27 of 1957).
Declaration not admissible in evidence against declarant - THE INCOME DECLARATION SCHEME, 2016 - Notwithstanding anything contained in any other law for the time being in force, nothing contained in any declaration made under section 180 shall be admissible in evidence against the declarant for the purpose of any proceeding relating to imposition of penalty, other than the penalty leviable under section 182, or for the purposes of prosecution under the Income-tax Act or the Wealth-tax Act, 1957 (27 of 1957).
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