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 Tribunal held that late filing fee u/s 234E was not leviable on the assessee. The assessee had filed the relevant return within the due date on 22.10.2021, which was acknowledged by the Central Processing Centre. The subsequent filing on 26.07.2022 was due to a technical glitch on the department's portal to facilitate issuance of TDS certificates for clients. The Tribunal ruled that the return filed on 22.10.2021 cannot be ignored, and late filing fee cannot be levied on the return filed on 26.07.2022. Consequently, the late filing fee imposed was deleted, and the assessee's appeal was allowed.
The Tribunal held that late filing fee u/s 234E was not leviable on the assessee. The assessee had filed the relevant return within the due date on 22.10.2021, which was acknowledged by the Central Processing Centre. The subsequent filing on 26.07.2022 was due to a technical glitch on the department's portal to facilitate issuance of TDS certificates for clients. The Tribunal ruled that the return filed on 22.10.2021 cannot be ignored, and late filing fee cannot be levied on the return filed on 26.07.2022. Consequently, the late filing fee imposed was deleted, and the assessee's appeal was allowed.
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