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/sec. 271(1)(c) - income disclosed in search action - Ex-parte order - The Tribunal observed that the assessee admitted to suppressed receipts, which were disclosed only after a search action and subsequent to the statement recorded under Section 132(4) of the Act. - The disclosure of suppressed receipts in the return filed under Section 153A of the Act did not absolve the assessee from penalty, as per legal precedent.
Penalty u/sec. 271(1)(c) - income disclosed in search action - Ex-parte order - The Tribunal observed that the assessee admitted to suppressed receipts, which were disclosed only after a search action and subsequent to the statement recorded under Section 132(4) of the Act. - The disclosure of suppressed receipts in the return filed under Section 153A of the Act did not absolve the assessee from penalty, as per legal precedent.
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