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...
Professional mis-conduct by CA - The NFRA held the individual guilty of professional misconduct under relevant sections of the Companies Act and imposed penalties. The appeal primarily raised concerns about the violation of natural justice due to the alleged non-provision of documents with the show cause notice. However, the Tribunal rejected this argument, citing the appellant's reliance on the firm's reply, which contained the necessary documents. - The Tribunal emphasized that by endorsing the firm's response as their own, the appellant waived the need for separate documents and hence dismissed the appeal.
Professional mis-conduct by CA - The NFRA held the individual guilty of professional misconduct under relevant sections of the Companies Act and imposed penalties. The appeal primarily raised concerns about the violation of natural justice due to the alleged non-provision of documents with the show cause notice. However, the Tribunal rejected this argument, citing the appellant's reliance on the firm's reply, which contained the necessary documents. - The Tribunal emphasized that by endorsing the firm's response as their own, the appellant waived the need for separate documents and hence dismissed the appeal.
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