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 petitioner was directed to pay a 5% penalty of the prevailing plot cost for the belated implementation of the project as per Clause 2.1.2.(a) of O.O.No.30 of 2020. However, the petitioner complied with the clause by utilizing more than 65% of the plot and had commenced production before dispatching goods. Despite paying the penalty amount, the petitioner was again directed to pay a 5% penalty. The Court found infirmity and illegality in the impugned order and quashed it, allowing the petition, as the petitioner had already paid the penalty and commenced production before dispatching goods, complying with all conditions.
The petitioner was directed to pay a 5% penalty of the prevailing plot cost for the belated implementation of the project as per Clause 2.1.2.(a) of O.O.No.30 of 2020. However, the petitioner complied with the clause by utilizing more than 65% of the plot and had commenced production before dispatching goods. Despite paying the penalty amount, the petitioner was again directed to pay a 5% penalty. The Court found infirmity and illegality in the impugned order and quashed it, allowing the petition, as the petitioner had already paid the penalty and commenced production before dispatching goods, complying with all conditions.
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