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 & 271E - allegation of cash loan having been taken/repaid - The ITAT underscored the principle that penalties under Sections 271D and 271E for violations of Sections 269SS and 269T are not applicable when the existence of the transactions (cash loans taken and repaid) is itself disputed. Furthermore, it highlighted the importance of adhering to principles of natural justice, including the right to cross-examine evidence used against the assessee.
Penalty u/s 271D & 271E - allegation of cash loan having been taken/repaid - The ITAT underscored the principle that penalties under Sections 271D and 271E for violations of Sections 269SS and 269T are not applicable when the existence of the transactions (cash loans taken and repaid) is itself disputed. Furthermore, it highlighted the importance of adhering to principles of natural justice, including the right to cross-examine evidence used against the assessee.
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