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 112(a) and Section 114AA of CA on Chartered Engineer - Issuance of Certificate under EPCG scheme without verification - The case involved the issuance of a Chartered Engineer Certificate for the installation and use of imported machinery under the EPCG scheme without verifying whether the machines were actually installed. The Department imposed penalties for non-compliance with verification requirements. The appellant argued good faith reliance on submitted documents and emphasized their limited role in verifying installation. However, the Tribunal held them liable for penalties, considering the seriousness of the offense.
Levy of penalty u/s 112(a) and Section 114AA of CA on Chartered Engineer - Issuance of Certificate under EPCG scheme without verification - The case involved the issuance of a Chartered Engineer Certificate for the installation and use of imported machinery under the EPCG scheme without verifying whether the machines were actually installed. The Department imposed penalties for non-compliance with verification requirements. The appellant argued good faith reliance on submitted documents and emphasized their limited role in verifying installation. However, the Tribunal held them liable for penalties, considering the seriousness of the offense.
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