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) - Failure to file the Return of Income (ITR) - The appellate tribunal addressed two appeals filed by the assessee against penalties imposed under section 271(1)(c) of the Income Tax Act for the assessment years 2011-12 and 2015-16. In the case of the former, the penalty was upheld, despite the appellant's argument of being a non-resident with limited knowledge of Indian tax laws. However, for the latter assessment year, the tribunal ruled in favor of the assessee, citing a similar precedent and considering the appellant's circumstances. The decision emphasized the importance of timely compliance with tax obligations and the relevance of the appellant's awareness of their tax liabilities.
Penalty u/s 271(1)(c) - Failure to file the Return of Income (ITR) - The appellate tribunal addressed two appeals filed by the assessee against penalties imposed under section 271(1)(c) of the Income Tax Act for the assessment years 2011-12 and 2015-16. In the case of the former, the penalty was upheld, despite the appellant's argument of being a non-resident with limited knowledge of Indian tax laws. However, for the latter assessment year, the tribunal ruled in favor of the assessee, citing a similar precedent and considering the appellant's circumstances. The decision emphasized the importance of timely compliance with tax obligations and the relevance of the appellant's awareness of their tax liabilities.
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