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 271D - loan in cash otherwise than an account payee cheque or draft - Assessee has placed on record only the ledger account, from that it is not clear whether the said transactions are considered as loan or the accommodative transactions or sales. It is also not clear whether the employer has received the cheque amount as sales consideration or as the amount as loan to employee in the books of the employer. This basic finding of the fact is not emanating from the records made available. - Matter restored back - AT
Penalty u/s 271D - loan in cash otherwise than an account payee cheque or draft - Assessee has placed on record only the ledger account, from that it is not clear whether the said transactions are considered as loan or the accommodative transactions or sales. It is also not clear whether the employer has received the cheque amount as sales consideration or as the amount as loan to employee in the books of the employer. This basic finding of the fact is not emanating from the records made available. - Matter restored back - AT
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