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 assessee was penalized u/s 271(1)(c) for addition of sale consideration due to lack of vouchers. The CIT(A) partly confirmed the addition for want of vouchers. The assessee argued that no penalty is maintainable as the transaction was truly disclosed, and long-term capital gains were reported. The ITAT held that the CIT(A) restricted the addition after examining the evidence, indicating the assessee succeeded partially. The AO imposed the penalty solely for non-submission of supporting vouchers. Relying on the CAFCO SYNDICATE SHIPPING CO. case, the ITAT ruled that penalty cannot be imposed for non-furnishing evidence as it does not amount to concealment of income. Consequently, the penalty levied by the AO was deleted, and the assessee's grounds were allowed.
The assessee was penalized u/s 271(1)(c) for addition of sale consideration due to lack of vouchers. The CIT(A) partly confirmed the addition for want of vouchers. The assessee argued that no penalty is maintainable as the transaction was truly disclosed, and long-term capital gains were reported. The ITAT held that the CIT(A) restricted the addition after examining the evidence, indicating the assessee succeeded partially. The AO imposed the penalty solely for non-submission of supporting vouchers. Relying on the CAFCO SYNDICATE SHIPPING CO. case, the ITAT ruled that penalty cannot be imposed for non-furnishing evidence as it does not amount to concealment of income. Consequently, the penalty levied by the AO was deleted, and the assessee's grounds were allowed.
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