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...
Levying penalty u/s. 271(1)(c) - The appellant, a partner in a partnership firm, had disclosed all particulars of income, including remuneration and interest on capitals received from the firm, in the original return filed. Despite the incorrect claim made under section 44AD of the Act, the Tribunal found no evidence of concealment or furnishing inaccurate particulars. Relying on legal precedents and considering the disclosure made by the appellant, the Tribunal concluded that the penalty was unwarranted.
Levying penalty u/s. 271(1)(c) - The appellant, a partner in a partnership firm, had disclosed all particulars of income, including remuneration and interest on capitals received from the firm, in the original return filed. Despite the incorrect claim made under section 44AD of the Act, the Tribunal found no evidence of concealment or furnishing inaccurate particulars. Relying on legal precedents and considering the disclosure made by the appellant, the Tribunal concluded that the penalty was unwarranted.
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