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 271(1)(c) - disallowances in the quantum assessment order - whether any concealment or furnishing of inaccurate particulars proved? - Tribunal directs deletion of penalty concerning disallowance under section 40(a)(ia) as the quantum appeal resulted in deletion of the addition. - Penalty in relation to unexplained investment and capital expenditure is remanded to the Commissioner of Income Tax (Appeals) for reconsideration post-quantum appeal decision. - Tribunal upholds penalty on foreign traveling expenses and commission payments, citing lack of evidence to establish business purpose or compliance with tax regulations.
Penalty u/s 271(1)(c) - disallowances in the quantum assessment order - whether any concealment or furnishing of inaccurate particulars proved? - Tribunal directs deletion of penalty concerning disallowance under section 40(a)(ia) as the quantum appeal resulted in deletion of the addition. - Penalty in relation to unexplained investment and capital expenditure is remanded to the Commissioner of Income Tax (Appeals) for reconsideration post-quantum appeal decision. - Tribunal upholds penalty on foreign traveling expenses and commission payments, citing lack of evidence to establish business purpose or compliance with tax regulations.
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