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 set aside the final assessment order and demand notice issued by the Income Tax department. The petitioner had filed an application u/s 35-A of the Income Tax Act manually, but failed to e-file the acknowledged copy of the application in Form No. 35-A despite repeated attempts between 29.12.2023 and 31.12.2023 due to technical glitches and bona fide reasons. The Court remitted the matter back to the Income Tax department for fresh reconsideration, accepting the petitioner's assertion that the failure to e-file was due to unavoidable circumstances and sufficient cause.
The High Court set aside the final assessment order and demand notice issued by the Income Tax department. The petitioner had filed an application u/s 35-A of the Income Tax Act manually, but failed to e-file the acknowledged copy of the application in Form No. 35-A despite repeated attempts between 29.12.2023 and 31.12.2023 due to technical glitches and bona fide reasons. The Court remitted the matter back to the Income Tax department for fresh reconsideration, accepting the petitioner's assertion that the failure to e-file was due to unavoidable circumstances and sufficient cause.
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