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...
Waiver of interest u/s 234A, 234B and 234C - marginal delay in filing the returns - The petitioner sought relief based on the timing of filing returns after receiving audit reports and financial challenges faced by the cooperative society. - The High Court, after careful consideration of submissions and legal principles, granted partial relief by waiving interest under Section 234A for certain assessment years. However, it refused to grant waivers under Sections 234B and 234C, emphasizing the importance of adhering to statutory timelines for tax payments.
Waiver of interest u/s 234A, 234B and 234C - marginal delay in filing the returns - The petitioner sought relief based on the timing of filing returns after receiving audit reports and financial challenges faced by the cooperative society. - The High Court, after careful consideration of submissions and legal principles, granted partial relief by waiving interest under Section 234A for certain assessment years. However, it refused to grant waivers under Sections 234B and 234C, emphasizing the importance of adhering to statutory timelines for tax payments.
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