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 High Court quashed the order rejecting the issuance of Form 5 under the Direct Tax Vivad se Vishwas Act, 2020 (DTVSV Act) and directed the respondent to issue Form 5 to the petitioner within twelve weeks. The petitioner had paid the entire amount except Rs. 1,533/- within the specified time period on or before 30th September, 2021. The delay of twelve days in payment of Rs. 1,533/- was considered unintentional and supported by a justifiable reason. The petitioner had also paid the difference of the amount payable after 30th September, 2021. The Court held that permitting the petitioner the benefit of the Scheme would not amount to extending or modifying the Scheme, which is the prerogative of the Government.
The High Court quashed the order rejecting the issuance of Form 5 under the Direct Tax Vivad se Vishwas Act, 2020 (DTVSV Act) and directed the respondent to issue Form 5 to the petitioner within twelve weeks. The petitioner had paid the entire amount except Rs. 1,533/- within the specified time period on or before 30th September, 2021. The delay of twelve days in payment of Rs. 1,533/- was considered unintentional and supported by a justifiable reason. The petitioner had also paid the difference of the amount payable after 30th September, 2021. The Court held that permitting the petitioner the benefit of the Scheme would not amount to extending or modifying the Scheme, which is the prerogative of the Government.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4800
Join Channel
TaxTMI 
