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...
Delayed filing of SIMS and LMPC certificates was treated as a procedural import-compliance lapse because the certificates were eventually produced and the record did not show mala fide intent or intent to evade. On that basis, the redemption fine and penalty under section 112(a)(i) were moderated, with the fine reduced to Rs. 1,00,000 and the penalty reduced to Rs. 50,000. Penalty under section 114AA was set aside because that provision applies only to knowingly or intentionally false or incorrect documents or statements, and no evidence established such knowledge or intent.
Delayed filing of SIMS and LMPC certificates was treated as a procedural import-compliance lapse because the certificates were eventually produced and the record did not show mala fide intent or intent to evade. On that basis, the redemption fine and penalty under section 112(a)(i) were moderated, with the fine reduced to Rs. 1,00,000 and the penalty reduced to Rs. 50,000. Penalty under section 114AA was set aside because that provision applies only to knowingly or intentionally false or incorrect documents or statements, and no evidence established such knowledge or intent.
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