Opportunity to furnish unsecured-loan confirmations is required before reassessment initiation; proceedings require fresh consideration after taxpayer...
Under-reporting on a first reassessment return attracts penalty, while enhanced misreporting penalty requires proof of a statutory misreporting catego...
ITAT ruled AMP expenses did not constitute international transaction under Section 92B, as Revenue failed to establish existence of arrangement between assessee and AE regarding AMP expenses. Following precedents from Maruti Suzuki India Ltd. and Bausch & Lomb cases, ITAT determined Transfer Pricing Officer lacked authority to make adjustments under Chapter X absent machinery provisions for AMP expenses. However, on excess refund claim, ITAT ruled against assessee, upholding that DTAA provisions are inapplicable when domestic company pays DDT under Section 115-O, following Total Oil India precedent. Appeal partially allowed favoring assessee on AMP issue while dismissing excess refund claim.
ITAT ruled AMP expenses did not constitute international transaction under Section 92B, as Revenue failed to establish existence of arrangement between assessee and AE regarding AMP expenses. Following precedents from Maruti Suzuki India Ltd. and Bausch & Lomb cases, ITAT determined Transfer Pricing Officer lacked authority to make adjustments under Chapter X absent machinery provisions for AMP expenses. However, on excess refund claim, ITAT ruled against assessee, upholding that DTAA provisions are inapplicable when domestic company pays DDT under Section 115-O, following Total Oil India precedent. Appeal partially allowed favoring assessee on AMP issue while dismissing excess refund claim.
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TaxTMI 
TaxTMI 
of 4915 
