Transfer pricing comparables selection and working capital adjustment u/r 10B(1)(e)(iii), remanded for recomputation with rejected comparables include...
Company oppression/mismanagement petition amendments and maintainability after alleged share transfer and forgery claims; tribunal order quashed for l...
Where an assessee obtained a certificate under the Direct Tax Dispute Resolution Scheme, 2016, the settlement order under s. 204(1) was held conclusive under s. 204(3), barring reopening of matters covered by it under the Act. Consequently, immunity from penalty proceedings operated generally, making it immaterial whether penalty would otherwise fall under s. 271AAB or s. 271AB. A revision initiated on audit objection to direct a de novo penalty order on the premise of applying a different penalty provision was unsustainable, and no substantial question of law arose. - HC
Where an assessee obtained a certificate under the Direct Tax Dispute Resolution Scheme, 2016, the settlement order under s. 204(1) was held conclusive under s. 204(3), barring reopening of matters covered by it under the Act. Consequently, immunity from penalty proceedings operated generally, making it immaterial whether penalty would otherwise fall under s. 271AAB or s. 271AB. A revision initiated on audit objection to direct a de novo penalty order on the premise of applying a different penalty provision was unsustainable, and no substantial question of law arose. - HC
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