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...
Rectification of mistake - Levy penalty u/s 271AAC or u/s 270 - No proceedings are pending before the CIT(A) - CIT (A) was not right in passing order of rectification by directing to initiate the penalty proceedings u/s 270A in place of penalty proceedings u/s 271AAC when admittedly vide her initial order dated 28.02.2022 has categorically held that addition made on account of alleged unaccounted sale u/s 68 is totally unjustified and consequently not covered u/s 115BBE of the Act and there was no income chargeable to tax under section 115BBE. - AT
Rectification of mistake - Levy penalty u/s 271AAC or u/s 270 - No proceedings are pending before the CIT(A) - CIT (A) was not right in passing order of rectification by directing to initiate the penalty proceedings u/s 270A in place of penalty proceedings u/s 271AAC when admittedly vide her initial order dated 28.02.2022 has categorically held that addition made on account of alleged unaccounted sale u/s 68 is totally unjustified and consequently not covered u/s 115BBE of the Act and there was no income chargeable to tax under section 115BBE. - AT
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