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...
The ITAT, an Appellate Tribunal, considered the issue of penalty u/s 271G in a case involving Transfer Pricing (TP) adjustment. The assessee did not initially provide segment-wise results for international transactions but later submitted the information to the TPO upon query. Despite this, the TPO imposed a penalty u/s 271G without proposing any Arm’s Length Price adjustment. The ITAT noted precedents where penalties were deleted in similar cases. The CIT(A) also referred to relevant decisions and deleted the penalty, citing the substantial compliance by the assessee, the nature of the diamond trade, and the absence of any Arm’s Length Price adjustment. The ITAT upheld the CIT(A)'s decision, dismissing the revenue's grounds for appeal.
The ITAT, an Appellate Tribunal, considered the issue of penalty u/s 271G in a case involving Transfer Pricing (TP) adjustment. The assessee did not initially provide segment-wise results for international transactions but later submitted the information to the TPO upon query. Despite this, the TPO imposed a penalty u/s 271G without proposing any Arm’s Length Price adjustment. The ITAT noted precedents where penalties were deleted in similar cases. The CIT(A) also referred to relevant decisions and deleted the penalty, citing the substantial compliance by the assessee, the nature of the diamond trade, and the absence of any Arm’s Length Price adjustment. The ITAT upheld the CIT(A)'s decision, dismissing the revenue's grounds for appeal.
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