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) - non compliance to statutory notice u/s 143(2) - there was irregularity in disposing of the objection raised by the assessee against re-opening u/s 147 r.w.s. 148 of the Act which was after four months. Therefore there is irregularity on the part of AO also, which we have observed with the help of sequence of events narrated above, therefore, we note that there is sufficient compliance on the part of assessee to response such notices. - No penalty - AT
Penalty u/s 271(1)(b) - non compliance to statutory notice u/s 143(2) - there was irregularity in disposing of the objection raised by the assessee against re-opening u/s 147 r.w.s. 148 of the Act which was after four months. Therefore there is irregularity on the part of AO also, which we have observed with the help of sequence of events narrated above, therefore, we note that there is sufficient compliance on the part of assessee to response such notices. - No penalty - AT
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