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...
Imposition of personal penalty on the Partner of the Firm in terms of Section 78A of the Finance Act, 1994 - The case involved the imposition of a personal penalty on one of the partners of a partnership firm for alleged tax evasion. The tribunal ruled in favor of the appellant, stating that there was insufficient evidence to hold them personally liable and citing extenuating circumstances affecting tax payments. Additionally, the validity of a supplementary agreement absolving the appellant from liability was questioned, leading to a decision in favor of the appellant.
Imposition of personal penalty on the Partner of the Firm in terms of Section 78A of the Finance Act, 1994 - The case involved the imposition of a personal penalty on one of the partners of a partnership firm for alleged tax evasion. The tribunal ruled in favor of the appellant, stating that there was insufficient evidence to hold them personally liable and citing extenuating circumstances affecting tax payments. Additionally, the validity of a supplementary agreement absolving the appellant from liability was questioned, leading to a decision in favor of the appellant.
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