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...
Acquittal of charge u/s 276CC - respondent has failed to comply with the provisions contained u/s 139(1) and he has submitted the income tax returns after a delay of 28 months - The High Court concluded that the prosecution failed to establish beyond reasonable doubt that the respondent had the requisite mens rea to evade tax. Considering the explanations provided by the respondent regarding the delay in filing income tax returns, the court found no evidence of deliberate wrongdoing. The court upheld the judgment of the trial court, acquitting the respondent of the charges under Section 276CC of the Income Tax Act, 1961.
Acquittal of charge u/s 276CC - respondent has failed to comply with the provisions contained u/s 139(1) and he has submitted the income tax returns after a delay of 28 months - The High Court concluded that the prosecution failed to establish beyond reasonable doubt that the respondent had the requisite mens rea to evade tax. Considering the explanations provided by the respondent regarding the delay in filing income tax returns, the court found no evidence of deliberate wrongdoing. The court upheld the judgment of the trial court, acquitting the respondent of the charges under Section 276CC of the Income Tax Act, 1961.
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