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...
Offence punishable u/s 276CC - failure to file the return of income (ITR) - in the instant case on hand, there is no evasion of tax. It is not the case that no return has been filed. In fact, return has been filed and refund has also been ordered. - there is no willful failure on the part of the petitioner to file return. Therefore, offence u/s 276 CC would not be attracted - HC
Offence punishable u/s 276CC - failure to file the return of income (ITR) - in the instant case on hand, there is no evasion of tax. It is not the case that no return has been filed. In fact, return has been filed and refund has also been ordered. - there is no willful failure on the part of the petitioner to file return. Therefore, offence u/s 276 CC would not be attracted - HC
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4827 
Join Channel 
