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...
Waiver of interest u/s 234A, 234B and 234C - Interest assessed on account of non-payment of advance tax - prayer for waiver of Interest declined as that late assessee (Husband of the Petitioner) had furnished incorrect particulars in Form 15-H in order to avoid the payment of taxes - The court concluded that (Late) assessee's actions, including filing returns promptly upon receiving notices and depositing tax liabilities, did not constitute voluntary filing without detection. However, it recognized his age and illiteracy as relevant factors constituting unavoidable circumstances. - The court quashed the order of the Chief Commissioner, waived the interest demanded, and set aside subsequent proceedings under Section 140 of the Income Tax Act.
Waiver of interest u/s 234A, 234B and 234C - Interest assessed on account of non-payment of advance tax - prayer for waiver of Interest declined as that late assessee (Husband of the Petitioner) had furnished incorrect particulars in Form 15-H in order to avoid the payment of taxes - The court concluded that (Late) assessee's actions, including filing returns promptly upon receiving notices and depositing tax liabilities, did not constitute voluntary filing without detection. However, it recognized his age and illiteracy as relevant factors constituting unavoidable circumstances. - The court quashed the order of the Chief Commissioner, waived the interest demanded, and set aside subsequent proceedings under Section 140 of the Income Tax Act.
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