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...
Penalty under section 272A(1)(d) for non-compliance with notices under section 142(1) was held not exigible where the assessee sought adjournments, stated that the information was under compilation, and later furnished the required details. The Tribunal noted that the scrutiny assessment was completed under section 143(3) on the returned income itself, so the matter did not involve persistent default or a best judgment assessment under section 144. On these facts, the penalty was quashed.
Penalty under section 272A(1)(d) for non-compliance with notices under section 142(1) was held not exigible where the assessee sought adjournments, stated that the information was under compilation, and later furnished the required details. The Tribunal noted that the scrutiny assessment was completed under section 143(3) on the returned income itself, so the matter did not involve persistent default or a best judgment assessment under section 144. On these facts, the penalty was quashed.
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