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 73 - non willful mis-statement - discrepancies found on the returns - Validity of notice uploaded in the common portal and not communicated physically - The High court acknowledged the petitioner's assertion that they possess the necessary documents to refute the alleged discrepancies and are willing to submit them. - The court allowed the writ petition, setting aside the impugned order. The matter was remanded back to the respondent for fresh consideration. The petitioner was directed to appear before the respondent with the required documents on a specified date, and the respondent was instructed to reconsider the issue promptly.
Levy of Penalty u/s 73 - non willful mis-statement - discrepancies found on the returns - Validity of notice uploaded in the common portal and not communicated physically - The High court acknowledged the petitioner's assertion that they possess the necessary documents to refute the alleged discrepancies and are willing to submit them. - The court allowed the writ petition, setting aside the impugned order. The matter was remanded back to the respondent for fresh consideration. The petitioner was directed to appear before the respondent with the required documents on a specified date, and the respondent was instructed to reconsider the issue promptly.
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