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 u/s 271(1)(c) - The assessee had short term capital gain on sale of land which was wrongly claimed as long term capital gain by substituting year of acquisition as 1999 instead of 2004 and said mistake was not brought to the notice of AO suo moto. In this background penalty was confirmed - penalty deleted since the assessee had a bonafide belief - AT
Penalty u/s 271(1)(c) - The assessee had short term capital gain on sale of land which was wrongly claimed as long term capital gain by substituting year of acquisition as 1999 instead of 2004 and said mistake was not brought to the notice of AO suo moto. In this background penalty was confirmed - penalty deleted since the assessee had a bonafide belief - AT
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