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) - loss on sale of machinery - The Assessee contested the penalty, arguing that the omission of adding the loss on the sale of machinery to the total income was a bona fide mistake. The Tribunal observed a contradictory stand between the financial statement and the computation of income, indicating inadvertent errors. Considering the Assessee's participation in penalty proceedings and the submission of relevant documents, the Tribunal concluded that the penalty imposition was not justified.
Penalty u/s 271(1)(c) - loss on sale of machinery - The Assessee contested the penalty, arguing that the omission of adding the loss on the sale of machinery to the total income was a bona fide mistake. The Tribunal observed a contradictory stand between the financial statement and the computation of income, indicating inadvertent errors. Considering the Assessee's participation in penalty proceedings and the submission of relevant documents, the Tribunal concluded that the penalty imposition was not justified.
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