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...
Levy of penalty u/s 234E - delay of 484 days in filling Form No. 26Q (TDS Return) - technical glitches on the part of the system - The ITAT allowed the appeals, focusing on the legal and technical nuances presented. The tribunal found that the appeals were filed within the extended limitation period provided by the Supreme Court due to the COVID-19 pandemic. It also highlighted that the technical issues faced by the assessee in filing TDS returns were not considered by the CIT(A), which led to an unjust imposition of late fees.
Levy of penalty u/s 234E - delay of 484 days in filling Form No. 26Q (TDS Return) - technical glitches on the part of the system - The ITAT allowed the appeals, focusing on the legal and technical nuances presented. The tribunal found that the appeals were filed within the extended limitation period provided by the Supreme Court due to the COVID-19 pandemic. It also highlighted that the technical issues faced by the assessee in filing TDS returns were not considered by the CIT(A), which led to an unjust imposition of late fees.
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