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...
Extended period of limitation - penalty - The material facts were unearthed by the Department and hence, non-furnishing of any facts would clearly amount to suppression of acts with an intention to evade tax within the meaning of Section 73(1) ibid. Hence, the Revenue is justified in invoking the larger period of limitation for this activity. So, the demand and penalty in respect of this activity are, therefore, required to be sustained. - AT
Extended period of limitation - penalty - The material facts were unearthed by the Department and hence, non-furnishing of any facts would clearly amount to suppression of acts with an intention to evade tax within the meaning of Section 73(1) ibid. Hence, the Revenue is justified in invoking the larger period of limitation for this activity. So, the demand and penalty in respect of this activity are, therefore, required to be sustained. - AT
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