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 assessee, a foreign-based company, initially failed to comply with the notice u/s 92D(3) within the statutory period of 60 days, responding on 25.03.2019 after a delay of 38 days. However, the Income Tax Appellate Tribunal (ITAT) considered the delay as minuscule and the reasons for non-compliance as bona fide and unintentional, given the peculiar circumstances of the assessee being a foreign entity and in the process of appointing a new authorized representative. The ITAT held that the penalty u/s 271G for non-compliance should be deleted, accepting the assessee's reasons for the inadvertent delay as reasonable. Consequently, the assessee's appeal against the penalty was allowed.
The assessee, a foreign-based company, initially failed to comply with the notice u/s 92D(3) within the statutory period of 60 days, responding on 25.03.2019 after a delay of 38 days. However, the Income Tax Appellate Tribunal (ITAT) considered the delay as minuscule and the reasons for non-compliance as bona fide and unintentional, given the peculiar circumstances of the assessee being a foreign entity and in the process of appointing a new authorized representative. The ITAT held that the penalty u/s 271G for non-compliance should be deleted, accepting the assessee's reasons for the inadvertent delay as reasonable. Consequently, the assessee's appeal against the penalty was allowed.
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