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) - TP adjustment - TPO included Government Companies which are now cannot be treated as good comparable as per certain decisions - if these will be excluded, Arithmetic mean is approximate to the working of the assessee hence it is not a case of concealment of income or furnishing of the inaccurate particulars - assessee has acted in good faith and with due diligence so no penalty is leviable
Penalty u/s 271 (1)(c) - TP adjustment - TPO included Government Companies which are now cannot be treated as good comparable as per certain decisions - if these will be excluded, Arithmetic mean is approximate to the working of the assessee hence it is not a case of concealment of income or furnishing of the inaccurate particulars - assessee has acted in good faith and with due diligence so no penalty is leviable
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