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 deleted the penalty levied u/s 271(1)(b) for non-compliance with a notice issued u/s 142(1) during reassessment proceedings. Considering the extraordinary circumstances of the Covid-19 pandemic, lockdowns, and the suffering caused, the Tribunal held that the department should have taken a liberal view in condoning the default. The assessee's non-compliance was covered u/s 273B, read with Section 271(1)(b), as Section 271(1)(b) is subject to Section 273B. The assessee's appeal was allowed, and the penalty was deleted.
The Income Tax Appellate Tribunal deleted the penalty levied u/s 271(1)(b) for non-compliance with a notice issued u/s 142(1) during reassessment proceedings. Considering the extraordinary circumstances of the Covid-19 pandemic, lockdowns, and the suffering caused, the Tribunal held that the department should have taken a liberal view in condoning the default. The assessee's non-compliance was covered u/s 273B, read with Section 271(1)(b), as Section 271(1)(b) is subject to Section 273B. The assessee's appeal was allowed, and the penalty was deleted.
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