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 case involves the computation of interest under section 234B for defaults in payment of advance tax. The Appellate Tribunal held that interest was correctly charged under section 234B(1) for the 36-month period from April 2010 to March 2013 based on the first assessment under section 153A. The subsequent appellate order only impacts the assessed income and tax liability, not the period for interest levy. Section 234B(3) applies when there is no first-time assessment under section 147/153A. Interest is to be charged based on the tax liability determined in the appellate proceedings for the mentioned 36-month period. The AO is directed to recompute interest in line with the Tribunal's order, allowing the assessee to raise objections if needed to avoid further litigation.
The case involves the computation of interest under section 234B for defaults in payment of advance tax. The Appellate Tribunal held that interest was correctly charged under section 234B(1) for the 36-month period from April 2010 to March 2013 based on the first assessment under section 153A. The subsequent appellate order only impacts the assessed income and tax liability, not the period for interest levy. Section 234B(3) applies when there is no first-time assessment under section 147/153A. Interest is to be charged based on the tax liability determined in the appellate proceedings for the mentioned 36-month period. The AO is directed to recompute interest in line with the Tribunal's order, allowing the assessee to raise objections if needed to avoid further litigation.
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