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...
Ratification of resignation acceptance validates separation retrospectively, while withdrawal may be refused through reasoned administrative discretio...
Cash received as sale consideration on registration of immovable property deeds was held outside the mischief of section 269SS, because the provision was applied to advances in property transactions and not to completed transfer consideration duly reflected in registered documents. On that footing, penalty under section 271D could not be sustained. The Tribunal also held that valid initiation of penalty required recorded satisfaction by the Assessing Officer in the assessment or other proceedings, and no such satisfaction was shown on the record. The penalty was therefore quashed and deleted.
Cash received as sale consideration on registration of immovable property deeds was held outside the mischief of section 269SS, because the provision was applied to advances in property transactions and not to completed transfer consideration duly reflected in registered documents. On that footing, penalty under section 271D could not be sustained. The Tribunal also held that valid initiation of penalty required recorded satisfaction by the Assessing Officer in the assessment or other proceedings, and no such satisfaction was shown on the record. The penalty was therefore quashed and deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4817 
Join Channel 
