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...
Reasonable cause under Section 273B operates to preclude imposition of penalties under Sections 271D and 271E where the assessee demonstrably shows bona fide belief and genuineness of transactions; thus deposit of cash in bank accounts, explained as bona fide and not motivated to avoid tax, furnished a reasonable cause and led to relief from penalties. The tribunal applied the ordinary prudence standard for 'reasonable cause'-a cause beyond the assessee's control, without negligence or lack of bona fides-and allowed the appeal on that basis.
Reasonable cause under Section 273B operates to preclude imposition of penalties under Sections 271D and 271E where the assessee demonstrably shows bona fide belief and genuineness of transactions; thus deposit of cash in bank accounts, explained as bona fide and not motivated to avoid tax, furnished a reasonable cause and led to relief from penalties. The tribunal applied the ordinary prudence standard for 'reasonable cause'-a cause beyond the assessee's control, without negligence or lack of bona fides-and allowed the appeal on that basis.
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