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 270A - misreporting of the income - disallowances of 40A(3) on account of interest income in the other sources and has also disallowed the claim of the assessee u/s 32 disputing the period use of the asset of the assessee - The Tribunal emphasized the distinction between assessment and penalty proceedings and noted that the mere addition in assessment did not automatically imply concealment. The ITAT also highlighted the appellant's compliance with depositing the demand within the stipulated time frame, albeit the procedural lapse in filing Form No. 68. Ultimately, the Tribunal ruled in favor of the appellant, directing the deletion of the penalty levied under section 270A of the Act.
Penalty u/s 270A - misreporting of the income - disallowances of 40A(3) on account of interest income in the other sources and has also disallowed the claim of the assessee u/s 32 disputing the period use of the asset of the assessee - The Tribunal emphasized the distinction between assessment and penalty proceedings and noted that the mere addition in assessment did not automatically imply concealment. The ITAT also highlighted the appellant's compliance with depositing the demand within the stipulated time frame, albeit the procedural lapse in filing Form No. 68. Ultimately, the Tribunal ruled in favor of the appellant, directing the deletion of the penalty levied under section 270A of the Act.
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