Jurisdictional sanction requirements bar reassessment when approval comes from an authority lacking statutory competence under the applicable framewor...
Recorded sales receipts cannot be reassessed as unexplained cash credits, eliminating the basis for consequential alleged commission expenditure addit...
Sufficient cause for delayed income-tax appeals requires bona fide diligence; unsubstantiated counsel illness and assessee inaction defeat condonation...
TNMM Segmentation Limits Transfer-Pricing Adjustments to Associated-Enterprise Transactions and Requires Turnover-Based Comparable Selection for IT Se...
Internal TNMM supports deletion of freight-forwarding adjustments where comparable non-AE transactions are separately identifiable and materially simi...
Penalty u/s 271G - assessee applied TNMM for determining of ALP - information/documents sought for determining of ALP as per CUP method - the difficulty in maintaining the information sought by the TPO has been well explained and analysed - allegation of the TPO that by non furnishing of documents has prevented him from determining the ALP under CUP method is unacceptable when he has accepted the benchmarking of the assessee - no penalty
Penalty u/s 271G - assessee applied TNMM for determining of ALP - information/documents sought for determining of ALP as per CUP method - the difficulty in maintaining the information sought by the TPO has been well explained and analysed - allegation of the TPO that by non furnishing of documents has prevented him from determining the ALP under CUP method is unacceptable when he has accepted the benchmarking of the assessee - no penalty
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
