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)(b) - Manner of service of notice - there is no mentioning of reasons by the A.O. in the assessment order as to why the Notice has to be served through affixture and the A.O. has not mentioned anything regarding efforts of ‘due and reasonable diligence to serve the notice’ on the assessee as required under rule 17 of order V of the CPC, thus the Service of Notice by way of affixture on the Assessee cannot be construed as sufficient Service of Notice. - AT
Penalty u/s 271(1)(b) - Manner of service of notice - there is no mentioning of reasons by the A.O. in the assessment order as to why the Notice has to be served through affixture and the A.O. has not mentioned anything regarding efforts of ‘due and reasonable diligence to serve the notice’ on the assessee as required under rule 17 of order V of the CPC, thus the Service of Notice by way of affixture on the Assessee cannot be construed as sufficient Service of Notice. - AT
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