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...
Transfer pricing adjustment on AMP expenditure was deleted because the Bright Line Test could not be applied to determine arm's length price, following Delhi High Court and coordinate Bench precedent; the Tribunal held no adjustment was warranted on the assessee's AMP spend. The section 43B issue on bonus payment was not decided on merits and was remitted to verify whether the bonus was paid within the return-filing due date, in which case no addition would arise. Claims relating to short grant of self-assessment tax credit and deduction of interest on VAT duty were also restored for fresh examination. The appeal was thus partly allowed.
Transfer pricing adjustment on AMP expenditure was deleted because the Bright Line Test could not be applied to determine arm's length price, following Delhi High Court and coordinate Bench precedent; the Tribunal held no adjustment was warranted on the assessee's AMP spend. The section 43B issue on bonus payment was not decided on merits and was remitted to verify whether the bonus was paid within the return-filing due date, in which case no addition would arise. Claims relating to short grant of self-assessment tax credit and deduction of interest on VAT duty were also restored for fresh examination. The appeal was thus partly allowed.
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TaxTMI 
TaxTMI 
of 4915 
