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 for non-compliance with statutory notices under section 271(1)(b) is not sustainable where the assessee establishes reasonable cause under section 273B. The Tribunal accepted that the assessee was not a regular taxpayer, was unaware of the income-tax proceedings and portal-related compliance, and learnt of the ex parte assessment only after demand was raised. It also noted that the quantum matter had already been restored to the AO. On these facts, the defaults in responding to the notices were treated as sufficiently explained, and the penalty was deleted.
Penalty for non-compliance with statutory notices under section 271(1)(b) is not sustainable where the assessee establishes reasonable cause under section 273B. The Tribunal accepted that the assessee was not a regular taxpayer, was unaware of the income-tax proceedings and portal-related compliance, and learnt of the ex parte assessment only after demand was raised. It also noted that the quantum matter had already been restored to the AO. On these facts, the defaults in responding to the notices were treated as sufficiently explained, and the penalty was deleted.
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