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...
ITAT adjudicated a tax penalty case involving under-reported income. The tribunal upheld the lower appellate authority's order deleting penalty u/s 270A. Since the primary quantum addition related to section 80P deduction was eliminated, no substantial under-reported income was established. Consequently, the penalty could not be sustained. The revenue's appeal was dismissed, confirming that the prerequisite conditions for imposing penalty under section 270A were not satisfied based on the factual matrix presented.
ITAT adjudicated a tax penalty case involving under-reported income. The tribunal upheld the lower appellate authority's order deleting penalty u/s 270A. Since the primary quantum addition related to section 80P deduction was eliminated, no substantial under-reported income was established. Consequently, the penalty could not be sustained. The revenue's appeal was dismissed, confirming that the prerequisite conditions for imposing penalty under section 270A were not satisfied based on the factual matrix presented.
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