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 Income Tax Appellate Tribunal allowed the assessee's appeal and held that there was a reasonable cause for the failure to furnish the audit report as required u/s 44AB of the Income Tax Act. The accountant responsible for maintaining the firm's accounts had abruptly resigned before finalizing the accounts for the relevant year. Upon rejoining after being offered a revised salary, the accountant completed the accounts, which were subsequently audited and filed. The Tribunal considered the explanations offered by the assessee and found that the conduct demonstrated a reasonable cause for the failure as per Section 273B. The assessee had committed only a technical breach without any loss to the government's exchequer, as no additions were made during the assessment proceedings.
The Income Tax Appellate Tribunal allowed the assessee's appeal and held that there was a reasonable cause for the failure to furnish the audit report as required u/s 44AB of the Income Tax Act. The accountant responsible for maintaining the firm's accounts had abruptly resigned before finalizing the accounts for the relevant year. Upon rejoining after being offered a revised salary, the accountant completed the accounts, which were subsequently audited and filed. The Tribunal considered the explanations offered by the assessee and found that the conduct demonstrated a reasonable cause for the failure as per Section 273B. The assessee had committed only a technical breach without any loss to the government's exchequer, as no additions were made during the assessment proceedings.
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